Hello,
Among this week's highlights are more warnings about relying on unverified Artificial Intelligence (AI) output, the latest employment status tribunal decision, HMRC’s view on the VAT liability of public electric vehicle charge points and the First Tier Tribunal's (FTT) interpretation of the Statutory Residence Test.
In Omar Rafique v HMRC [2026] TC09874, the First Tier Tribunal (FTT) found that an application to reinstate a struck-out VAT appeal should be refused. The appellant had persistently failed to comply with tribunal directions and 'Unless Orders', and had repeatedly submitted AI-generated correspondence containing fabricated case authorities.
In Professional Game Match Officials Limited v HMRC [2026] TC09870, the First Tier Tribunal (FTT) found that referees engaged by the company were not employees. The long-standing case emphasises the 'multi-factorial' approach required when determining employment status.
In Michael Parker v HMRC [2026] TC09868, the First Tier Tribunal (FTT) found that days spent in the UK by an overseas engineer travelling between Iraq, the UK, and holiday destinations could be excluded under the transit days and exceptional circumstances provisions.
In Sarah Thomas v HMRC [2026] TC09861, the First Tier Tribunal (FTT) found that a debt assignment from a company to a shareholder was taxable as an income distribution to the extent that it exceeded the shareholder's loan account. A lack of documentary evidence for the loan account and an obstructive approach did not help the taxpayer.
Hello,
Close company directors within Self Assessment have additional reporting obligations in their 2025-26 tax returns. We have expanded our commentary on the new requirements in our 'Self Assessment Return 2025/26: What's new?' guide this week, including how percentage shareholdings should be calculated. Do take a look, as the rules might not be as expected.
Some taxpayers may have noticed changes to their digital tax coding notice when they log in to their accounts. HMRC began trialling the changes from mid-March and it will continue into June.
HMRC have updated their Tax Agent Handbook in anticipation of the introduction of Multi-Factor Authentication (MFA) when logging into Agent Accounts.
HMRC have released new guidance on what happens if an unregistered or suspended tax adviser interacts with HMRC. Further guidance has also been released on what advisers can do if they disagree with HMRC's decision about their registration.
In HMRC v MR Currell Limited [2026] EWCA Civ 445, the Court of Appeal (CoA) agreed with an Upper Tribunal (UT) decision which ruled that a loan to an Employee Benefit Trust was not taxable as earnings.
