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Articles by Philip Harle
Stamp Holiday for IPOs | JD Supra
The government has in today's budget announced a 3 year stamp tax holiday for UK company IPOs The government has in today's budget announced a 3 year stamp tax holiday for UK company IPOs with effect from tomorrow. The UK is unusual in levying stamp tax (technically stamp duty and stamp duty reserve tax (“SDRT”)) on transfers of shares at the relatively high rate of 0.5% of the price paid for the shares.
Replacement of Energy Profits Levy with the Oil and Gas Price Mechanism | JD Supra
As announced in the Autumn 2024 budget, the Energy Profits Levy (EPL) will end on 31 March 2030 (or earlier if oil and gas prices fall below a certain threshold under the Energy Security Investment Mechanism). It will be replaced by a permanent tax called the Oil and Gas Price Mechanism (“OGPM”) which will only apply during periods of high oil and gas prices. The rate of OGPM will be 35%.
Soft Drinks Industry Levy: The ‘Milkshake Tax’ | JD Supra
One expected measure, announced on 25th November, is the so-called 'milkshake tax' which will extend the Soft Drinks Industry Levy (“SDIL”), the UK's tax on high sugar pre-packaged drinks, to sugary milk and milk-substitute products such as certain flavoured milks and ready-to-drink coffees. The threshold also will be lowered to 4.5g of sugar per 100ml.
Replacement of Energy Profits Levy with the Oil and Gas Price Mechanism
It will apply to upstream oil and gas companies operating in the UK/UKCS (broadly, companies which are subject to Ring Fence Corporation Tax) on the realised price the company receives for disposal of oil and gas above the relevant thresholds. There will be two thresholds, one for oil and one for gas, which will apply per financial year. The thresholds for 2026/2027 will be $90 per a barrel for oil and 90p per a therm for gas.
Soft drinks industry levy: the ‘milkshake tax’
The threshold also will be lowered to 4.5g of sugar per 100ml. A lower 4g sugar threshold was initially proposed in a consultation earlier in 2025 but has been rejected following industry feedback on the difficulties of reformulating drinks below this threshold.
Stamp holiday for IPOs
The government has in today's budget announced a 3 year stamp tax holiday for UK company IPOs with effect from tomorrow. The UK is unusual in levying stamp tax (technically stamp duty and stamp duty reserve tax (“SDRT”)) on transfers of shares at the relatively high rate of 0.5% of the price paid for the shares.
UK VAT on insurance intermediary services – exemption expanded? | JD Supra
The Court of Appeal (CA) in WTGIL Ltd v HMRC [2025] EWCA Civ 399 considered the scope of the VAT exemption for services supplied by insurance intermediaries. The case concerned motor insurance for young drivers which required the policyholders to have a “black box” device fitted in their car. The question before the CA was whether the services of the provision and fitting of the device were within the scope of the insurance intermediary exemption for VAT purposes. The CA decided that they were.
Pillar Two: a practical review
Whilst the majority of the legislation implementing Pillar Two into UK law has been in force for over a year, 2025 is the year in which in-scope groups will be beginning to prepare their first Pillar Two tax returns and making accounting provisions for Pillar Two taxes. Read our article for a back to basics guide on the regime and its impact on UK business (originally published in Tax Advisor). Article attached. Authored by Philip Harle and Laura Hodgson.
Third time lucky? 1.5% UK stamp tax vs “Brexit 3.0” - update | JD Supra
November 28, 2023 Katharine Crossman, Philip Harle, Adam Parry Hogan Lovells + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: Draft UK legislation was previously published proposing to remove the 1.5% stamp tax charge on issues, and certain transfers, of securities to depositary receipt systems and clearance services (or their nominees) currently scheduled to be resurrected on 1 January 2024 by the Retained EU Law (Revocation and...
Third time lucky? 1.5% UK stamp tax vs “Brexit 3.0” - update
Draft UK legislation was previously published proposing to remove the 1.5% stamp tax charge on issues, and certain transfers, of securities to depositary receipt systems and clearance services (or their nominees) currently scheduled to be resurrected on 1 January 2024 by the Retained EU Law (Revocation and Reform) Act 2023.
UK Stamp Taxes – Removal of 1.5% “Brexit” charge – in the nick of time? | JD Supra
September 15, 2023 Katharine Crossman, Philip Harle, Adam Parry Hogan Lovells + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: New draft UK legislation has been published today proposing to remove the 1.5% stamp tax charge on issues, and certain transfers, of securities to depositary receipt systems and clearance services (or their nominees) currently scheduled to be resurrected on 1 January 2024 by the Retained EU Law...
UK Stamp Taxes - Removal of 1.5% “Brexit” charge - in the nick of time?
New draft UK legislation has been published today proposing to remove the 1.5% stamp tax charge on issues, and certain transfers, of securities to depositary receipt systems and clearance services (or their nominees) currently scheduled to be resurrected on 1 January 2024 by the Retained EU Law (Revocation and Reform) Act 2023. These provisions are expected to be enacted in the Finance Bill 2023-24 (likely Q1 2024), but with commencement from 1 January 2024 (subject to certain timing concerns).
Other cases that caught our eye: 4 November 2022
Home >Articles > Other cases that caught our eye: 4 November 2022 1 November 2022 Oil ring-fence: The decision of the Court of Appeal of the Falkland Islands in Sentinel Marine Falkland Islands Ltd v The Commissioner of Taxation (SC/CIV/03/21) (12 October 2022) concerns the scope of the oil ring-fence in the Falkland Islands....
R&D tax credits: arrests made
Home >Articles > R&D tax credits: arrests made R&D tax credits: arrests made 2 November 2022 In response to media coverage about R&D tax credits, HMRC has confirmed that eight people have been arrested on the suspicion of conspiring to submit over 100 fraudulent R&D relief claims. ‘The arrests include a tax agent suspected of criminally facilitating the fraudulent attack. More arrests are expected in the coming days.
Why political parties implode and what tax has to do with it
Looking at the political chaos of the last two months, you might be forgiven for thinking that this sort of instability is endemic in the UK. However, a different perspective would be to look at the political landscape since 1979. There were 18 years of Conservative rule followed by 13 years of Labour rule and so far, 12 years on Conservative dominated rule. Taking the long view and downplaying the distractions of social media and the 24-hour news cycle shows a different perspective.
Victoria Atkins MP appointed as FST
Home >Articles > Victoria Atkins MP appointed as FST Victoria Atkins MP appointed as FST 2 November 2022 Victoria Atkins MP was appointed to the role of financial secretary to the Treasury on 27 October 2022. Her portfolio will include responsibility for tax policy and customs. Atkins takes over from Andrew Griffith who moves to the role of economic secretary to the Treasury.
HMRC campaign to target offshore corporates
Home >Articles > HMRC campaign to target offshore corporates HMRC campaign to target offshore corporates 2 November 2022 HMRC intends to launch a campaign in November 2022 targeting non-compliance linked to offshore corporates owning property in the UK. Originally, HMRC had aimed to kick things off in September.
Lucky Technology v HMRC
Home >Articles > Lucky Technology v HMRC Lucky Technology v HMRC 1 November 2022 Input VAT claims allowed on vouchers In Lucky Technology v HMRC [2022] UKFTT 366 (TC) (22 September 2022), the FTT held that VAT could be recovered on the purchase of vouchers from a concession in Harrods. The case brings together two areas of VAT law which are notoriously complex and...
C4C Investments Ltd v HMRC
Home >Articles > C4C Investments Ltd v HMRC C4C Investments Ltd v HMRC 1 November 2022 Taxpayer’s application to amend grounds of appeal rejected In C4C Investments Ltd v HMRC [2022] UKFTT 367 (TC) (11 October 2022), the FTT denied the taxpayer permission to amend its grounds of appeal, holding that the application was late, the proposed new grounds had no realistic prospect of success, and...
HMRC manual changes: 28 October 2022
Home >Articles > HMRC manual changes: 28 October 2022 26 October 2022 This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors. Manual Page Comments Capital Gains Manual Updated: CG-APP18–110 More information added to...
One minute with... Philip Harle
Home >Articles > One minute with... Philip Harle One minute with... Philip Harle 5 October 2022 One minute with Philip Harle, tax partner at Hogan Lovells and is chair of the City of London Law Society Revenue Law Committee. What do you know now that you wish you’d known at the start of your career? Today’s Bitcoin price! Seriously, I think it would have been helpful to know that over 20 years later I would still find tax, and legal practice generally, to be fascinating.
Important changes to DAC6 regime in the UK: impact on bank lending transactions | JD Supra
The UK has made important changes to its implementation of the EU Mandatory Tax Disclosure Rules known as DAC6. The changes, which significantly reduce the scope of the rules in the UK, are largely good news for UK taxpayers and their advisers. The effect is that DAC6 reports will be required more rarely from intermediaries or taxpayers in the UK.
Beyond Brexit transition – possible VAT benefit for securitisations | JD Supra
UK securitisations using an EU-based securitisation vehicle may get a VAT benefit post-Brexit transition. Currently, VAT on securitisation costs is likely irrecoverable for UK originators. VAT-exempt servicing by the originator would block input VAT recovery. Whilst VAT recovery is already specifically allowed for input tax attributable to VAT-exempt servicing supplied to counterparties outside the EU, UK securitisations generally use either UK or EU-based issuers.
Tech Tax – Looking Forward to 2020 | JD Supra
Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such seemingly dry topics so relevant to tech companies? It’s because their dynamism and continual state of change almost inevitably have tax consequences, or attract attention from tax authorities.
Tech Tax – Looking Forward to 2020 | LexBlog
Following-up from our previous blogs on Tech Tax, we thought it would be useful to take a whirlwind tour of what to expect in tax and transfer pricing related topics in 2020. But for those that are curious, why are such seemingly dry topics so relevant to tech companies? It’s because their dynamism and continual state of change almost inevitably have tax consequences, or attract attention from tax authorities.
Tech Tax – Times Are A Changing? | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Automotive in the United Kingdom | Lexology
Overview Market Describe the significance of, and developments in, the automotive industry in the market. The automotive industry is a significant contributor to the UK economy, generating an annual manufacturing turnover of £77.5 billion in 2017 which, based on the first two quarters’ figures for 2018 is set to increase. The industry employed some 814,000 people in the wider industry in 2017, and this figure is also increasing in 2018.
Amending debt instruments – 3 tax questions to consider | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
Automotive in the United Kingdom | Lexology
Use the Lexology Getting The Deal Through tool to compare the answers in this article with those from other jurisdictions. Overview Market Describe the significance of, and developments in, the automotive industry in the market. The automotive industry is a significant contributor to the UK economy, generating an annual turnover of £77.5 billion and employing some 814,000 people.
FATCA tweaks kick "Passthru" withholding back to the future | JD Supra
Updated: May 25, 2018: JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.
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