2024–25—Fiscal events including Budget

This subtopic draws together content on the fiscal events throughout the tax year 2024–25, including:

•
Tax Administration and Maintenance Day (TAMD), which took place on 18 April 2024
•
Tax legislation day (L Day), which took place on 29 July 2024
•
Autumn Budget, which took place on 30 October 2024, and
•
the publication of the Autumn Finance Bill 2024 (AFB 2024), also known as Finance Bill 2025 and Finance Bill 2024–25, which was published on 7 November 2024

For more information on the annual Budget and Finance Bill process, including how a general election affects the usual timetable, see Practice Note: The Budget and Finance Bill process.

All analysis produced in this subtopic will be collected in Practice Notes: 2024–25—Fiscal events including Budget—Tax Analysis and Tax—Finance Bill 2025 tracker .

Tax Administration and Maintenance Day (TAMD)

TAMD took place on 18 April 2024. None of the TAMD announcements required legislation in Finance (No 2) Act 2024.

For more information on the announcements and publications from TAMD, see:

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News

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Latest Tax News

Tax weekly highlights—12 December 2024

This week's edition of Tax weekly highlights includes: (1) key announcements from the draft Welsh Budget 2025–26, (2) analysis of the Court of Appeal’s decision in Axa Sun Life plc v HMRC, and (3) the UT’s decision in HMRC v Colchester Institute Corporation.

UT follows previous decision on VAT treatment of government-funded education programmes (HMRC v Colchester Institute Corporation)

Tax analysis: In HMRC v Colchester Institute Corporation [2024] UKUT 397 (TCC) (4 December 2024) the Upper Tribunal (UT) dismissed HMRC’s appeal against a decision of the First-tier Tax Tribunal (FTT) that the government-funded provision of further and higher education and vocational training constituted a supply of services for consideration for VAT purposes because there was a direct link between the services and the consideration.

When will a ‘GLO issue’ bind all parties on the group register? (Axa Sun Life plc v HMRC)

Dispute Resolution analysis: The Court of Appeal has clarified when a decision on a ‘GLO issue’ will bind parties on the group register, and when the court will exercise its discretion to ‘order otherwise’ under CPR 19.23(1). As a general rule, determination of a GLO issue will bind all other parties on the group register at the relevant time. The court needs a strong reason to depart from that general rule. The principles of res judicata found in issue estoppel provide a helpful guide to when the court can depart from the general rule and ‘order otherwise’. Written by Harriet Campbell, senior knowledge lawyer at Penningtons Manches Cooper LLP.

FTT decides sale of LLP capital accounts not subject to income tax (Hoyle and others v HMRC)

Tax analysis: In Hoyle, the First-tier Tax Tribunal (FTT) held that the anti-avoidance provisions in Chapter 5 of Part 13 of the Income Tax Act 2007 (ITA 2007) did not apply to the disposal of the appellants’ capital accounts in limited liability partnerships (LLPs) engaged in leasing film rights. This was because, following the judgment in Samarkand v HMRC [2017] EWCA Civ 77, as a matter of fact and law, the LLPs film leasing activity was not a trading activity for tax purposes.