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Tax weekly highlights—13 February 2025

Published on: 13 February 2025

Table of contents

  • Companies and corporation tax
  • Supreme Court upholds Court of Appeal’s decision that UK-Canada DTT did not give the UK taxing rights over the assigned payments (Royal Bank of Canada v HMRC)
  • Employment taxes
  • HMRC updates Employment Status Manual
  • Changes to size thresholds for off payroll working
  • Updated bonus rates for Save As You Earn share option schemes
  • International
  • FTT denies cross-border group relief claim on main purpose grounds (Lloyds Asset Leasing v HMRC)
  • Social Security (Contributions) (Amendment) Regulations 2025 have been made and come into force on 6 April 2025
  • The Designation of Special Tax Sites (East Midlands Investment Zone) Regulations 2025 have been made and come into force on 26 February 2025
  • More sections of this document available when you sign-in to Lexis+ or register for a free trial.

Article summary

This week's edition of Tax weekly highlights includes: (1) the Supreme Court decision in Royal Bank of Canada that the UK-Canada DTT did not give the UK taxing rights over the assigned oil-related payments, (2) HMRC updating the Employment Status Manual for the Supreme Court decision in PGMOL, and (3) News Analysis on the FTT decision in Lloyds Asset Leasing.

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