Tax information exchange and FATCA

FORTHCOMING CHANGES: The UK is due to implement the OECD’s Cryptoasset Reporting Framework (CARF) into domestic law with effect from 1 January 2026. The implementing measure is the Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744), which was laid before the House of Commons on 25 June 2025. On the same day, HMRC published tax impact and information notes (TIIN) for the measure. HMRC has also published guidance on reporting under the CARF.

The government has also introduced legislation amending the domestic law implementing the OECD’s Common Reporting Standard (CRS) and the UK’s obligations under the Intergovernmental Agreement with the US for the implementation of the US Foreign Account Tax Compliance Act (FATCA). The principal legislation is the International Tax Compliance Regulations 2015 (SI 2015/878) and the amending measure is the International Tax Compliance (Amendment) Regulations 2025 (SI 2025/740). The amendments implement the OECD’s 2023 changes to the CRS and introduce other changes ‘to make the UK’s implementation of the rules more effective’ (Explanatory Memorandum, para 5.5). The principal changes are to include e-money

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Latest Tax News

Tax weekly highlights—30 October 2025

This week's edition of Tax weekly highlights includes: (1) News Analysis on the Supreme Court’s decision in Northumbria Healthcare, (2) News Analysis on the UT’s decision in Illuminate Skin Clinics, (3) a CIOT technical update on the small profits rate and non-UK resident companies, and (4) the making of regulations bringing in various aspects of the Economic Crime and Corporate Transparency Act 2023.

Supreme Court decides that NHS Trust should have charged VAT on the provision of car parking at hospitals (Northumbria Healthcare NHS Foundation Trust v HMRC)

Tax analysis: The Supreme Court unanimously allowed HMRC’s appeal, ruling that Northumbria Healthcare NHS Foundation Trust was not acting under a ‘special legal regime’ (SLR) when operating its hospital car parks and was therefore required to charge VAT. The Court clarified that external guidance, combined with the general public law obligation to adhere to it in the absence of good reason, was insufficient to amount to an SLR. As well as summarising the decision, this News Analysis contains commentary from Bryn Reynolds, Partner at Pinsent Masons LLP, on the implications of the judgment.

FTT partially allows appeal in respect of VAT input tax claims (Eurocent (Buckingham) Ltd v HMRC)

Tax analysis: In Eurocent (Buckingham) Ltd v HMRC, the First-tier Tax Tribunal (FTT) allowed the appellant’s appeal in part, finding that certain invoices met the statutory requirements for the contents of a valid VAT invoice. The FTT also rejected HMRC’s contention that it was entitled to reject input tax claims, using its discretion under the VAT Regulations 1995, SI 1995/2518, reg 29(2), even if the VAT invoice was valid.

UT considers scope of VAT exemption for medical care (Illuminate Skin Clinics Ltd v HMRC)

Tax analysis: In Illuminate Skin Clinics Ltd v HMRC, the Upper Tribunal (UT) allowed the appellant’s appeal against a First-tier Tax Tribunal (FTT) decision that certain aesthetic, skincare and wellness treatments provided by a qualified doctor were not exempt supplies of medical care for VAT purposes. The UT held that the FTT erred in law by placing no weight on consultation records as evidencing diagnoses of recognised health disorders. The UT remitted the case to the FTT to be remade.