The Finance Bill has been published and there is quite a lot in it. We will be working our way though it in the coming weeks.

A couple of new measures and consultations caught my eye. The disguised remuneration rules are being extended to include sole traders and partners. We have a response on PSCs and an updated guide below.

The proposals in 'Tackling offshore tax evasion: A requirement to notify HMRC of offshore structures' will be interesting if ever implimented. Many wealthy non-doms use offshore trusts to invest in their different companies around the world with the benefit of keeping their non-UK income out out of the UK's tax coffers. It is uncertain how HMRC would be able to work out whether those structures are being used for tax evasion even if notified. The government has a dilemma: push through a crowd pleaser or try and attract wealthy non-doms. I think we can guess what the tabloids will say, although the irony is that many of the papers that shout the loudest about tax abuse are actually owned by the very people who use those offshore structures.

We have an R&D case where the FTT disagreed with HMRC's interpretation of late payment of subcontractor costs. It will be interesting to see whether HMRC will update its R & D manual, as the FTT imposes harsher payment rules than HMRC.

We have grass roots sports (fancy sponsoring your son's team?) and sugar tax. We also have an update on our close company loans to participators toolkit. We have been seeing a lot of issues around loans in recent months. It seems that many company owners have difficulties with these rules.

Enjoy the guides and updates and the news is below. 

Back soon

Nichola Ross Martin FCA Tax Director


Your Virtual Tax Partner®: online PRACTICAL support for accountants & tax advisers BY accountants & tax advisers

Quick news (freeview)

Finance Bill 2017 published
The first draft of the Finance Bill 2017 has been published on 5 December 2016.

Disguised remuneration: Finance Bill 2017 changes
Finance Bill 2017 introduces more rules to target disguised remuneration, including a charge on all remaining untaxed loans and extending the rules to the self-employed and partners.

We are hiring
We are looking for CVs for Private Client and we also looking for individuals/firms who have particular SME tax specialisms too. Tax in a totally unique business.

New consultations

Notifying HMRC about offshore structures
HMRC have opened a consultation ‘Tackling offshore tax evasion: A requirement to notify HMRC of offshore structures’ as part of their ongoing offshore tax evasion strategy.

EIS & SEIS advance assurance
HMRC have opened a consultation ‘Tax-advantaged venture capital schemes – streamlining the advance assurance service’ in response to increased demand for the service.

Scope of VAT Grouping
HMRC have opened a consultation ‘Scope of VAT Grouping’ to review aspects of the UK’s VAT grouping arrangements following decisions of the European Court. 

Consultation responses

PSCs and the public sector
HMRC have published a response to their consultation earlier this year on ‘Off-payroll working in the public sector: reform of the intermediaries legislation’.

Ultra low emissions company cars
HMRC have published a response to their consultation earlier this year on ‘Company car tax for ultra low emission cars (ULEV)’. 

Case Update (freeview)

FTT disagrees with HMRC over R & D payment timings
In Gas Recovery and Recycle Ltd v HMRC [2016] TC05473 the First Tier Tribunal (FTT) took a different interpretation of the payment timing rules to HMRC. It nevertheless denied a claim for R&D relief.  

VAT group recovers MBO input VAT
In Heating Plumbing Supplies Ltd v HMRC [2016] TC05480 the First Tier Tribunal (FTT) found that input VAT relating to a management buyout was recoverable by the VAT group. 

ATED penalty appeal: notices defective
In Chartridge Developments Ltd v HMRC [2016] TC05493 the First Tier Tribunal (FTT) cancelled penalties for late submission of ATED Returns. HMRC's penalty notices penalty notices contained incorrect filing dates.

Closure notices: appeal strike out rejected
In B&K Lavery Property Trading Partnership v HMRC [2016] UKUT 0525 the Upper Tribunal (UT) rejected an application to strike out an appeal on the grounds that HMRC had raised an argument not included in their closure notice.

Practical Tax Guides and Updates (subscribers) 

Disguised remuneration
UPDATED: our revamped guide brings together everything you need to know about the current rules and proposed changes in Finance Bill 2017 and beyond.

ISA Guide
UPDATED for draft legislation on Lifetime ISA.

Northern Ireland Corporation Tax Rate
NEW A Corporation Tax rate for Northern Ireland of 12.5% could be introduced from April 2018.  Our guide sets out how the rates will apply to SMEs and large companies. 

Annual Tax on Enveloped Dwellings
UPDATED for charges applicable from 1 April 2017. 

Furnished Holiday Letting
UPDATED more details added on use of losses when FHL status is lost.

Grassroots Sports Contributions
NEW: A guide to the new corporation tax deduction for contributions to grassroots sports introduced by Finance Bill 2017. 

Soft Drinks Industry Levy    
NEW: Finance Bill 2017 includes the first draft legislation of the new levy which will be introduced from April 2018, including guidance for small drinks producers.

Editor's Choice: CPD

Close company loans toolkit (loans to participators)
Have a read through: lots of people are being caught out by the different rule changes in recent years.

Personal Service Companies (PSC)
PCS have taken a battering this year and the future is not looking so good either. We explain the changes and the current proposals. 

Incorporation: start here
Guides and links to take your through the process of incorporating an existing business or a new company.

CPD Webinars

Latest webinars: CPD for lunch

Missed last time's update?

Nichola's SME Tax Update 2 December 2016


  • Land & Property Update
  • VAT Flat Rate Scheme: limited cost trader
  • SDLT & residential property: higher rate
  • Travel: employer's guide
  • Directors Tax Planning Toolkit 2016/17
  • CIOT & ATT new CPD regulations

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