Tax law

At Autumn Budget 2024, the government announced several reforms to agricultural property relief and business property relief from Inheritance Tax, including a £1 million allowance which will apply to the combined value of property that qualifies for 100% business property relief or 100% agricultural property relief or both.

The consultation document invites views on how the changes will apply to property settled into trust.

The Finance and Public Administration Committee carried out a short, focussed inquiry on how the Scottish budget process has worked in practice, during the parliamentary session (2021-26).

It aims to identify any improvements that can be made to the budget process, ahead of the next five-year session of Parliament.

The focus of the inquiry will be on the four core objectives that underpin the Scottish budget process:

  • to have greater influence on the formulation of the Scottish Government’s budget proposals
  • to improve transparency and raise public understanding and awareness of the budget
  • to respond effectively to new fiscal and wider policy challenges
  • to lead to better outputs and outcomes as measured against benchmarks and stated objectives.

 

The UK Government issued a consultation on Inheritance Tax on pensions and is seeking views on the processes required to implement changes. 

 

The Scottish Government has launched a consultation seeking views on the proposed introduction of a Building Safety Levy on new residential development in Scotland.

 

The UK Government issued a consultation to seek views on the impact of applying 20% VAT to private school fees across the UK and removing the business rates charitable rates relief for private schools. 

  • View the policy paper on the UK Government's website. 
  • Read our response. 

Our Tax Law Sub-committee provided written feedback to the Finance and Public Administration Committee of the Scottish Parliament in relation to its Pre-Budget Scrutiny 2025-26. 

  • Read more on the Scottish Parliament website here. 
  • Read our consultation response here.  

Our Tax Law Sub-committee provided written evidence to the Finance and Public Administration Committee of the Scottish Parliament in relation to its consideration of the (draft) Land and Buildings Transaction Tax (Miscellaneous Amendments) (Scotland) Order 2024. The draft Order was laid before the Scottish Parliament on 19 January 2024, and provides for a number of changes to the Land and Buildings Transaction Tax Additional Dwelling Supplement.

HM Revenue & Customs and HM Treasury consulted on elements of the tax treatment of ecosystem service markets and environmental land management. Part 1 of the consultation was a call for evidence on the tax treatment of the production and sale of ecosystem service units. Part 2 consulted on the scope of agricultural property relief from inheritance tax. 

In January 2024, we wrote a joint letter with the Association of Tax Technicians and ICAS to the Financial Secretary to the Treasury, detailing our concerns around ongoing uncertainties regarding the tax treatment in this area.

HM Revenue and Customs consulted on the proposed amendments to the Construction Industry Scheme (CIS) regulations. The regulations set out exceptions to VAT compliance obligations to ensure that Gross Payment Status is not refused or removed for minor errors, and exempt certain payments from landlords to tenants from the scope of the CIS.

Scottish Government Consultation

The Scottish Government consulted on proposed legislative amendments to the Land and Buildings Transaction Tax (Scotland) Act 2013, including the addition of a new schedule 16D, which will provide a relief from LBTT for qualifying non-residential transactions within a designated Green Freeport tax site.

The Land and Buildings Transaction Tax (Green Freeports Relief) (Scotland) Order 2023 (SSI 2023/Draft)

The draft SSI was laid before the Scottish Parliament on 16 June 2023. The Finance and Public Administration Committee launched a call for views on its provisions, which closed on 16 August 2023.

HM Revenue and Customs consulted on proposals to modernise the Stamp Taxes on Shares framework, which encompasses both Stamp Duty and Stamp Duty Reserve Tax.

HM Revenue and Customs consulted on possible changes to strengthen and simplify the Construction Industry Scheme (CIS).

Scottish Government established a new Tax Advisory Group, and we wrote a joint letter with ICAS to outline the strategic objectives that this new group should consider.

The Scottish Government launched a consultation on proposed legislative amendments to the arrangements for the Land and Buildings Transaction Tax (LBTT) Additional Dwelling Supplement (ADS). The consultation followed on from previous call for evidence and views on ADS in 2022.

The House of Commons' Treasury Committee held an inquiry on Tax Reliefs.

HMRC held a consultation seeking views on proposals to address consumer protection issues for individuals who claim tax repayments via repayment agents.

HMRC held a consultation seeking views on proposals to formalise and extend a concession that removes trusts and estates from Income Tax where the only source of income is savings interest, and the tax liability is below £100.

The Scottish Government launched a consultation seeking evidence and views on the operation of the Land and Buildings Transaction Tax (LBTT) Additional Dwelling Supplement (ADS). The Scottish Government committed to a review of the ADS in the 2021-22 Programme for Government. This call for evidence and views is the first stage of that review.

The UK Government launched a consultation seeking views on the introduction of a corporate re-domiciliation regime to support companies seeking to relocate to the UK.

The House of Lords' Finance Bill Sub-committee held an inquiry on the Draft Finance Bill 2021-22.

The UK Government issued a consultation seeking views on the draft legislation of the Residential Property Developer Tax ahead of its inclusion in the 2021-22 Finance Bill.

The Scottish Government issued a consultation to seeks view on their overarching approach to tax policy, through Scotland’s first framework for tax, and how they should use devolved and local tax powers as part of the Scottish Budget 2022 to 2023.

A call for evidence by HMRC to seek views on the current VAT rules relating to land and property, and explores potential options for simplifying them.

The UK Government issued a consultation to seek views on the proposal that everyone who provides tax advice should hold professional indemnity insurance, as well as views on a definition of tax advice.

The UK Government announced on 10 February 2021 that it would introduce a new Residential Property Developer Tax as part of its Building Safety Package. The tax is one of the government’s measures to bring an end to unsafe cladding, provide reassurance to homeowners and support confidence in the housing market. The government consulted on the design of that tax ahead of its inclusion in the 2021-22 Finance Bill.

The Office of Tax Simplification issued a consultation seeking views on Capital Gains Tax and suggestions for improvements.

The UK Parliament's Finance Bill Sub-Committee called for evidence on the draft Finance Bill 2020-2021, asking for views on three areas of the Bill: new proposals for tackling promoters and enablers of tax avoidance schemes; new tax checks on licence renewal applications; and amendments to HMRC’s civil information powers.

 

The UK government invited views on the principles and design of a new framework for Stamp Duty and Stamp Duty Reserve Tax (SDRT), both of which tax transactions in shares and securities.

The UK Parliament's Treasury Committee launched an inquiry called ‘Tax after coronavirus’ and sought evidence on what overall level of taxation the economy can bear, the role of tax reliefs in rebuilding the economy, and whether there is a role for windfall taxes in the post-coronavirus world.

The UK government called for evidence on ways to tackle future use of disguised remuneration tax avoidance.

The UK Government asked for views on proposals to strengthen the sanctions against those who promote or enable tax avoidance schemes.

The UK government issued a consultation calling for views on ways to raise standards and increase transparency in the tax advice market.

The UK Government asked for views on areas of the plastic packaging tax design, which have been further refined ahead of the tax commencing in April 2022.

The Finance and Constitution Committee agreed at its meeting on 6 February 2019 that Scottish Government officials working with the clerks establish a devolved taxes legislation working group to take forward the following recommendations of the Budget Process Review Group (BPRG).

The working group invited submissions in light of its interim report.

HM Revenue and Customs has published draft secondary legislation for technical comment. The draft secondary legislation relates to the reform of the off-payroll working rules, due to come into effect from 6 April 2020.

The UK Government invited the views of stakeholders for budget representations.

The Scottish Government has issued a consultation on the principles of a local discretionary Transient Visitor Levy or 'tourist tax'.

The Scottish Government has issued a consultation on a new approach to the planning, management and implementation of the fully devolved taxes in Scotland.

HM Revenue & Customs has issued a consultation on how the off-payroll working rules will work from April 2020.

The Scottish Government has issued a consultation setting out the principles for taxing trusts and seeks views and evidence on reform in line with them. 

Read our written evidence submitted to the Scottish Parliament's Finance and Constitution Committee on the Land and Buildings Transaction Tax (Tax Rates and Tax Bands Etc.) (Scotland) Amendment Order 2018.

HM Revenue & Customs has issued a consultation on the relevance of some of the information powers enacted by schedule 36 of the Finance Act 2008, and on potential improvements.

HM Treasury and HM Revenue & Customs have issued a consultation on the best way to tackle non-compliance with the off-payroll working rules (IR35) in the private sector.

The Scottish Government has issued a consultation on the potential introduction of reliefs from LBTT to bring parity with Stamp Duty Land Tax (SDLT) for certain types of authorised property investment funds.

HMRC have launched a consultation on tax abuse and insolvency.

The UK Parliament's treasury committee has launched an inquiry on the Conduct of Tax Enquiries and the Resolution of Tax Disputes.

The Office of Tax Simplification has issued a call for evidence with regards Inheritance Tax Review.

The Scottish Government has issued a consultation on an amendment to Land and Buildings Transaction Tax Group Relief.

The Scottish Government has issued a consultation on the first-time buyer relief from Land and Buildings Transaction Tax (LBTT), as announced in the draft Scottish Budget 2018/19.

HM Treasury and HM Revenue & Customs have issued a consultation on the tax treatment of gains accruing on disposals of interests in UK immovable property by non-residents, and Technical Note on accompanying anti-forestalling rule.

In anticipation of the Scottish Government’s proposed budget, the Tax Law Sub-Committee have submitted comments relating to devolved taxes.

Tax Law Sub-Committee

Our expert group on tax law.

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Our responses to consultations

Our responses to recent consultations on various areas of law.

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Influencing the law and policy

One of the main functions of our policy team, along with our network of volunteers, is to analyse and respond to proposed changes in the law.

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