For this month’s edition, Alex Sim joined Zoe Andrews to discuss three cases of the FTT: Dialog (the tax treatment of break fees), Boulting (purchase of own shares was not a distribution) and Ferrero (the VAT treatment of Nutella biscuits). The podcast then covers HMRC’s campaign on management expenses and HMRC’s policy (set out in Revenue & Customs Brief 6 (2025)) on VAT deduction on insurance intermediary services supplied outside the UK following the FTT’s decision earlier this year in Hastings Insurance. Alex and Zoe go on to explore various international developments including the OECD’s recent APA/MAP awards and France’s proposal to double the rate of its digital services tax.

Sarah Osprey joined Zoe Andrews and Tanja Velling to discuss trends in HMRC enquiries and the use of criminal investigation powers in a tax context.

The podcast then covers the Supreme Court’s decision in Prudential Assurance on the interaction between the VAT grouping and time of supply rules, and the CJEU’s decision in Arcomet Towercranes that transfer pricing adjustments can trigger VAT liabilities.

Sarah Osprey joined Zoe Andrews and Tanja Velling to talk about tax disputes and our exciting new project in this area.

The podcast further covers three decisions of the First-tier Tribunal:

• Currys Retail on the capital gains tax degrouping charge
• Millennium Cash & Carry, the first case on the so-called “sugar tax” which highlights the limits of statutory construction
• Motorplus on VAT recovery with the FTT commenting on HMRC’s extraordinary behaviour

Zoe and Tanja go on to discuss L-Day materials including draft legislation for inheritance tax on inherited pension and death benefits, HMRC’s increased powers to close in on promoters, and the mandatory registration requirement for tax advisers interacting with HMRC, as well as certain other UK and international tax developments.