Tax News: July 2025

Zoe Andrews and Tanja Velling discuss the following recent cases:

• Dolphin Drilling: the Supreme Court’s decision on the meaning of “incidental” should not be read as having wider application beyond the oil contractor regime
• Haworth (Court of Appeal) applying the place of effect management test to a trust in the context of a “round the world” capital gains tax scheme
• Marlborough DP (Court of Appeal) on the tax treatment of a remuneration structure involving loans made by a trust and the meaning of “in connection with” in Part 7A of ITEPA
• Osmond: the Upper Tribunal held that it was an error of law to equate seeking a capital gains tax relief with having a main purpose of obtaining an income tax advantage
• Eastern Power Networks (First-tier Tribunal), a cautionary tale on structuring to maximise consortium relief

The podcast also covers HMRC’s new guidance on advance pricing agreements for cost contribution arrangements, the government’s recently published tax policy making principles, Revenue & Customs Brief 4 (2025) on input tax recovery in respect of investment and administration costs linked to occupational pension funds and what’s next for Pillar Two.