Tax News Highlights - May 2023

In this podcast, Zoe Andrews and Tanja Velling discuss the Court of Appeal’s decision in McClean v Thornhill KC on duty of care in the context of tax advice, the First-tier Tribunal’s decision in Buckingham on the tax treatment of a US dividend, the Upper Tribunal’s decision in Spring Capital on whether questions of Scots law are questions of fact or law, and the Advocate General’s opinion in the Engie State aid case. They further discuss the consultations on the modernisation of stamp taxes on shares and the introduction of a new fund structure, the Reserved Investor Fund (Contractual Scheme), which were published as part of the Tax Administration and Maintenance Day on 27 April 2023. The podcast also covers the potential QDMTT safe harbour, the status of Pillar Two implementation across different jurisdictions, and a Brexit-related change to HMRC’s practice on late payment interest as well as an update on the Retained EU Law (Revocation and Reform) Bill.