Tax News

In this podcast, Catrin Young, Senior Professional Support Lawyer in the Pensions Team, joins Zoe Andrews and Tanja Velling to discuss the government’s policy decision at the Autumn Budget to bring unused pension savings and death benefits into the scope of inheritance tax (with the charge to be administered by pension trustees), and HMRC’s recent clarification that the authorised surplus payment charge payable by the trustees of a defined benefits scheme when returning a surplus to an employer is to be calculated by reference to the gross amount of the surplus (rather than the amount received by the employer). Zoe and Tanja also discuss the increase in late payment interest from April 2025, two updates to HMRC guidance, the UK expert panel’s report on a potential corporate re-domiciliation regime and certain international developments. The podcast further covers three UK cases: the First-tier Tribunal’s decision in Syngenta, denying interest deductions for a loan created in an intra-group reorganisation under the unallowable purpose rule in section 441 of the Corporation Tax Act 2009, and the Upper Tribunal’s decisions in Gould on the tax point for an interim dividend where two shareholders were paid around eight months apart, and in Panayi on conforming interpretation.