SME Tax News

Hello,

We have a good mix of cases this week, with yet another ‘wrong forms for SEIS’ case where this time the First Tier Tribunal (FTT) took a pragmatic approach and allowed shares to be issued under the Seed Enterprise Investment Scheme (SEIS) despite forms being incorrectly filed for Enterprise Investment Scheme (EIS) relief.

The temporary measures to support businesses from insolvency as a result of COVID-19 are being phased out from 1 October. New targeted measures are to be introduced to help smaller companies.

HMRC have issued their Agent Update for September 2021. We have summarised the key content for you with links to our detailed guidance on the topics covered.

The Office of Tax Simplification (OTS) has released a report entitled 'The UK tax year-end date: exploring the potential for change'. This report explores the benefits, costs and wider implications of a change to the UK's year-end tax date. 

In Kwik-Fit Group Limited v HMRC [2021] TC08226, the First Tier Tribunal (FTT) found that loans transferred between group companies following a reorganisation did not maintain their allowable purpose meaning the interest was disallowed.

In Marlborough DP Ltd v HMRC [2021] TC08246, the First Tier Tribunal (FTT) held that loans funded by a remuneration trust were not earnings, or disguised remuneration taxable under part 7A of ITEPA 2003. They were taxable as distributions so no Corporation Tax deductions could be claimed by the contributing company.

 

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