In this week’s miscellaneous updates, we bring you news that the Court of Justice of the European Union (CJEU) has overturned a European Commission decision that the UK’s controlled foreign company (CFC) rules were state aid. From this month HMRC has begun replacing some of its texts and SMS messages with what it refers to as “branded messages” and the latest issue of HMRC’s Public Service pensions Remedy newsletter has been published. Two new non-executive directors have also joined HMRC’s board, one of whom includes the former director of the Office of Tax Simplification, Bill Dodwell. And finally, HMRC has published more information ahead of the commencement of VAT being charged on private school fees from 1 January 2025.
CJEU decision says UK CFC finance company rules were not state aid
The CJEU recently ruled that the UK’s CFC rules were compatible with the internal market and set aside the judgment of the General Court, ordering the European Commission to pay the court costs for those involved in the appeal.
The case centred around whether the UK’s finance company exemption on the taxation of the non-trade finance profits of CFCs was tantamount to artificial diversion of profits and constituted state aid.
HMRC branded messages
From October 2024 HMRC has begun to replace some of the texts and SMS messages it sends to taxpayers with what it refers to as “branded messages”. These “branded messages” use some of the features of rich communications services, in order to “modernises and improves SMS messaging”. Although HMRC says that “branded message are more secure”, it continues to advise taxpayers to follow the published guidance on identifying suspicious contact.
VAT on private school fees
HMRC has published more information ahead of the commencement of VAT being charged on private school fees from 1 January 2025. This confirms that education providers will be able to register for VAT from 30 October 2024. More details are available in the following publications: