This week we are launching our new Transactions in Securities 'secret' weapon: the TAAR tool. 

A Targeted Anti-Avoidance Rule ('TAAR') in respect of distributions on winding up has been in place since 2016. Most of us understand the basics: this is a measure to deter the practice of 'phoenixing' companies, but we unfamiliar with the detail as we do not have enough clients winding up their companies to warrant studying the detail. That may well be about to change. 

The off-payroll working rules are set to apply to the private sector from 2020, many personal service company (PSC) owners are starting to re-evaluate their business models and many will be considering whether they still need their PSCs, or not. It you are a PSC owner or adviser, you need to know the TAAR rules. This is where our new tool can help. It shaves off about 2.5 hours in research and does the job in a couple of minutes. It does come with a health warning, and so it's sensible as a warm-up to read the accompanying notes first. 

Continuing our introduction to our new Reorganisations Zone, this week we have been looking at that aged-old problem: how do you extract an investment business, maybe a subsidiary, from your trading company? We provide some options for you to consider. One thing about the Reorganisation Zone is that a lot of the things we need to reorganise would, with the benefit of hindsight, never have been set up in that way had we fully worked through the consequences when we set them up. 'Always begin with the end in mind', if you can! We have updated our Exit Strategies index, run through that when you plan a new business.

On other news, Making VAT Digital: notice 700/22 has been updated by HMRC to slightly relax some aspects of digital record keeping and we have cherry picked some useful case decisions for you. 

If you have any tax queries please do try out our Virtual Tax Partner support portal at www.VtaxP.co.uk.

Enjoy the guides and updates and the news is below.

Back soon 

Nichola Ross Martin FCA CTA (Fellow) Tax Director


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

Making Tax Digital

New guidance on Making VAT digital
HMRC have amended VAT notice 700/22 to provide further guidance on the use of supplier statements, petty cash transactions and charity fundraising events.

Making Digital (for VAT) Zone
Who has to join? What records need to be kept? Do I need to change my bookkeeping system? 

Editor's Choice (subscribers)

Transactions in Securities (TIS) Index
What's new? What is a TIS? Case studies and illustrations

Targeted Anti-Avoidance Rule (TAAR) Tool
Ceasing trading? Phoenixing? Unsure? Do you understand the Transactions in Securities rules? Try the TAAR tool.

Exit strategies Index
Are selling your company or just ceasing trading? Start here.

Tax Guides and Updates (subscribers)

Reorganisation Zone: Start here
NEW: You can reorganise or separate company activities and different subsidiaries using a variety of different methods. This series of super practical tax guides provide an outline of the tax treatment together with step guides and tax clearance templates.

Case study 2: Tradeco: demerger of an investment subsidiary
What are the steps for a demerger of an investment business from a trading company? Template for tax clearance and case study.

Personal Service Companies (PSC)s
UPDATE: all the new and proposed tax rules affecting PSCs and their owners. 

Case Update (freeview)

ER success: Preference shares were Ordinary shares
In Stephen Warshaw v HMRC 2019 TC08674 the FTT allowed an appeal against £1,158,916 of CGT: cumulative compounding preference shares were ordinary shares for Entrepreneurs' Relief.

HMRC's delay frustrates Discovery Assessment
In Hargreaves v HMRC [2019] TC07090 the FTT held that HMRC's long delay in raising an assessment on an £84m capital gain meant that there was no 'discovery' and it was invalid.

English law on evidence trumps foreign confidentiality claim
In Bank Mellat v Her Majesty’s Treasury [2019] EWCA Civ 449 the Court of Appeal explored the interaction of English law and foreign laws in terms of access to sensitive evidence following a $4billion claim against the UK.

VAT Cases (freeview)

VAT registration required: Taxi firm owner was not an agent
In Bryn Williams v HMRC [2019] TC06963 the FTT held that a taxi firm owner should have registered for VAT; he was not acting as an agent for his drivers when contracting with local authorities.

Director fined for his company's failure to notify
In Stanley John Chmiel v HMRC [2018] TC7112 a company director’s failure to register his company for VAT resulted in a £4,250 penalty via a Personal Liability Notice. HMRC’s powers sometimes allow it to ‘pierce the corporate veil’.

Job and Opportunities in Tax

TaxAid and Tax Help for Older People
We are happy to promote some exciting job vacancies in tax for the amazing tax charities: TaxAid and Tax Help for Older People...More

Tax advisers
We are looking for tax advisers and consultants who are interested in flexible working, have practical experience in working in SME tax and are good at detail and happy to work in the team to keep making www.rossmartin.co.uk such a wonderful resource...More

Block of fees for sale
Small block of self assessment cases...More

CPD for lunch

Finance Act 2019
NEW: A webinar covering the latest legislative changes.

Missed last time's Web-update?

Nichola's SME tax W-update 3 May 2019


  • Launching our reorganisations Zone
  • Shares: what is an ordinary share?
  • Entrepreneurs relief on the disposal of a company
  • Purchase of own shares
  • Trusts & Estates Bulletin
  • and much more..

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