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It is ‘business as usual’ following exit day according to the EU Withdrawal Agreement (at least for matters covered by the agreement) and the government sets out its post-Brexit ambitions and priorities for the financial services sector. HMRC publishes further guidance on the interpretation of the hybrid capital instruments rules. The Upper Tribunal in Hicks finds that the taxpayer’s accountant was careless in completion of his tax returns and that the conditions for HMRC to raise a discovery assessment are met. Progress is made on the two pillars of international tax reform, with the agreed outline on Pillar One noting that there is a compelling case for retail banks and insurance to be outside the scope of the new taxing right. The latest HMRC statistics show, unsurprisingly, diverted profits tax receipts are down on last year but they also reveal that HMRC has concluded a number of older transfer pricing cases.
This article was first published in the 14 February 2020 edition of Tax Journal.