Securitisations

FORTHCOMING CHANGE relating to diverted profits tax: Following a consultation on the reform of transfer pricing, permanent establishment and diverted profits tax in 2023 (for which a summary of responses document was published in January 2024), the government published draft legislation for potential inclusion in Finance Bill 2026 containing measures to replace DPT as a standalone tax with a new charging provision within corporation tax for unassessed transfer pricing profits (UTPP), while maintaining the assessment framework from the DPT regime, including preliminary notices and charging notices, and the 6% differential tax rate between corporation tax and DPT. For more information, see Practice Notes: The Diverted Profits Tax—charge to tax and Tax—Finance Bill 2026 tracker—progress through Parliament.

FORTHCOMING CHANGE relating to the modernisation of stamp taxes on shares framework: Following the call for evidence in 2020, the resulting outcome published in 2021, consideration by the relevant HMRC and industry working group and the 2023 consultation, the government confirmed in the consultation outcome published on 28 April 2025 that, in 2027, it intends to replace stamp duty and SDRT with a single self-assessed stamp tax on securities, generally

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

TAKE A FREE TRIAL

Latest Tax News

Tax weekly highlights—27 November 2025

This week's edition of Tax weekly highlights includes: (1) the key tax announcements made in the government’s Budget on 26 November 2025, (2) News Analyses on the Court of Appeal’s decision in A D Bly Groundworks and Civil Engineering Ltd and the High Court’s decision in Jordi Carulla Font, and (3) Agent Update Issue 137.

CA upholds UT decision disallowing corporation tax deductions in relation to UURBS (A D Bly Groundworks and Civil Engineering v HMRC)

Pensions analysis: The Court of Appeal (CA) dismissed the taxpayers’ appeals against the decision of the Upper Tribunal (UT) finding that expenditure incurred by them was disallowed under section 54 of the Corporation Tax Act 2009 (CTA 2009), because it was not incurred ‘wholly and exclusively for the purposes of the trade’. The CA also upheld the decision of the UT on HMRC’s cross-appeal, that the expenditure was not disallowed under CTA 2009, s 1290. Written by Rebecca Murray, Barrister at Devereux Chambers.

Budget 2025—Private Client analysis

Private Client analysis: A summary of the key personal tax announcements made in the Chancellor’s Budget on 26 November 2025.

Budget 2025—Tax analysis

Tax analysis: A summary of the key business tax announcements made in the Budget on 26 November 2025. Expert comment provided by Addleshaw Goddard, Akin Gump Strauss Hauer & Feld, A&O Shearman, Andersen, Ashurst, Blick Rothenberg, Boodle Hatfield, Bryan Cave Leighton Paisner, Burges Salmon, CMS, Eversheds Sutherland, Fieldfisher, Lawrence Stephens, Macfarlanes, Pinsent Masons, Proskauer, Shoosmiths, Stephenson Harwood, Temple Tax Chambers and Travers Smith.