Tax information exchange and FATCA

FORTHCOMING CHANGES: At Autumn Budget 2024, the government published a summary of responses to a consultation on: (i) the UK’s implementation of the OECD’s Cryptoasset Reporting Framework (CARF); (ii) certain amendments to the Common Reporting Standard (CRS); and (iii) whether to make the UK a reportable jurisdiction for the purposes of the CRS and the CARF (ie introduce domestic reporting).

As a result, the government has: (i) published draft regulations implementing the CARF; (ii) published draft regulations amending the CRS; (iii) announced that the CARF will include domestic reporting (to be brought in when the CARF is implemented); and (iv) in contrast to (iii), stated that it will ‘continue to examine the issues raised’ regarding ‘the benefits and drawbacks of extending CRS reporting to cover UK customers of UK businesses’.

The government is now ‘seeking technical feedback on the draft regulations to ensure they operate as the government intends and to identify any areas which need further clarification in more detailed guidance’. The deadline for responses is 10 January 2025. HMRC will prepare the relevant guidance and ‘will work with stakeholders

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Tax weekly highlights—19 June 2025

This week's edition of Tax weekly highlights includes: (1) News Analyses on the FTT decisions in Eastern Power Networks, Moffat and Performance Leads, (2) HMRC’s new guidance on cost contribution agreements under the advance pricing agreement programme, (3) HMRC’s direction extending the deadline for making a final VAT return, (4) HMRC’s change of policy on VAT deductions in relation to the management of pension funds, and (5) HM Treasury’s policy paper on ‘Tax policy making principles’.

FTT rejects taxpayers’ claims for entrepreneurs’ relief (Moffat and another v HMRC)

Tax analysis: In Moffat, the First-tier Tax Tribunal (FTT) held that the taxpayers’ claims for entrepreneurs’ relief (now business asset disposal relief) on the disposal of shares in a company did not succeed because the company was not the holding company of a trading group. The FTT, however, allowed their appeal against penalties imposed by HMRC in respect of the claims, holding that the taxpayers had not behaved carelessly.

FTT finds that provision of ‘leads’ to independent financial advisors constituted VAT exempt financial intermediary services (Performance Leads Ltd v HMRC)

Tax analysis: In Performance Leads, the First-tier Tax Tribunal (FTT) allowed the taxpayer’s appeal that supplies of ‘lead generation’ services to independent financial advisors (IFAs) fell within the exemption from VAT for intermediary services in relation to financial services transactions.