Weekly tax highlights ― 3 February 2025

Produced by a Tolley Owner-Managed Businesses expert

Owner-Managed Businesses

Guidance

Direct taxes

Consultation: Multinational Top-up Tax and Domestic Top-up Tax: Supplementary draft guidance

HMRC has launched a consultation on supplementary draft guidance for Multinational Top-up Tax and Domestic Top-up Tax. This consultation will close on 8 April 2025.

HMRC is seeking views on the supplementary draft guidance, which includes sections on flow-through entities, joint ventures, the insurance sector, and additional top-up amounts. The draft also covers the undertaxed profits rule (UTPR) and other provisions amended or introduced in the current Finance Bill.

Stakeholders are invited to comment on this draft guidance and any previously released drafts. This consultation will close at 11:59pm on 8 April 2025, and it represents the final release of draft guidance before the publication of the manual.

See Simons Taxes D4.302; D4.320.

CIOT consultation response: Inheritance Tax on pensions: liability, reporting and payment

The CIOT has published its response to the consultation on the proposed inclusion of unused pension funds and death benefits within a person's estate for inheritance tax purposes from 6 April 2027.

The key points raised

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