Good news this week for some who received High Income Child Benefit Charge late notification penalties. A new Agent update and our Virtual Tax Partner Toolkit 'TAMI' expands.

We also feature, for subscribers our latest Directors' Tax Planning update and new CPD 'for lunch'. 

I have passed links to my MTD for VAT 'still trying' to sign up blog to various tax bodies, thank you for your comments. Keep reading and adding them as I have found some more workarounds. To be fair to HMRC, many of the glitches may be out of their control, different browsers do things differently.

An interesting selection of VAT cases are featured this week, although the direct tax company residence case is probably the most exciting. On VAT, VAT is a very difficult tax to get right. As the VAT cases show, week after week, there are so many known unknowns. Our summaries barely scrape the surface.

I have added a sign up form for our Virtual Tax Partner Toolkit so please do sign up and we can send out details to you on each tool or the whole toolkit and then arrange a demo. These new tax tools have a working nickname; meet TAMI. TAMI stands for 'tax artificial machine intelligence', the joke here being that that there is no machine intelligence at this stage, only human-generated algorithms.

If you have tax queries contact the Virtual Tax Partner support portal at www.VtaxP.co.uk.

Enjoy the guides and updates and the news is below. Subscribe now!

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

Quick news (freeview)

HMRC repays £1.8m in penalties to parents
HMRC have completed their review of cases where a failure to notify penalty was issued to taxpayers who did not register for the High Income Child Benefit Charge, repaying £1.8m in penalties.

Agent update June/July 2019
HMRC have issued the Agent Update for June/July 2019. We have summarised the key content for you with links to our detailed guidance on the topics covered.

UPDATE: still trying to sign up to MTD for VAT. Almost half there and the Agent Services Account seems to have been further enabled. There is the grim realisation that as HMRC sends out generic messages we cannot tell who is in or not.

Editor's Choice (subscribers)

Directors' Tax Planning: Update June 2019
NEW: A topical update of issues affecting directors, tax planning tips and potential problem areas.

Reorganisations Case Study 7: Creating a group  
What are the steps for creating a group by way of a share for share exchange? Week seven in our tour through out new Reorganisation Zone. A series of super practical tax guides provide an outline of the tax treatment together with step guides and tax clearance templates.

Virtual Tax Partner © Tax Toolkit© Tax Toolkit
NEW: be a winner with our game-changing tax diagnostics tools.

Tax Guides & Updates

Entrepreneurs' Relief (ER)
UPDATE: links to all our ER guides and the legislation (if you want to work it all out yourself!). 

Date of disposal
NEW: When is the date of disposal for Capital Gains tax purposes? When do special rules apply? Why does it matter? Our guide answers these questions and more.

IHT: Gifts Normal Expenditure out of income
UPDATE: includes proforma letter of gift

Private Residence Relief
UPDATE: now includes the three different proforma elections 

Case Update (freeview)

Capital loss scheme success: Jersey companies are not UK resident
In Development Securities plc & Others v HMRC [2019] UKUT0169 the UT held that Jersey companies were not UK resident; acting in the best interests of a parent company did not pass central management and control to the parent.

The cost of an earnout: no relief where tax is deferred
In David Briggs & Others v HMRC [2019] TC07166 the FTT held that a change in a right to earnout consideration from loan notes to cash was a disposal of that right and triggered the gain deferred on the original disposal.

VAT cases

Input tax partly recoverable for Opera House's production costs
In the Royal Opera House Covent Garden Foundation v HMRC [2019] TC7157 the FTT made a helpful analysis as to when taxable supplies can be directly associated with production costs for the purposes partial exemption allocation of residual input tax. 

Rebuilt Glasgow Student Union not a separate supply
In Glasgow School of Art v HMRC [2019] UKUT 0173 the Upper Tribunal held that construction of a new building and rebuilding of another were effectively treated at one building and a single supply for VAT. 

Payroll services exempted by welfare exemption
In Cheshire Centre for Independent Living v HMRC TC7182 the FTT found that a supply of payroll services to disabled people was so closely linked to the provision of welfare services that payroll charges were VAT exempt.

CPD for lunch

Structures and Buildings Allowance (SBA)
NEW: Will the SBA prove to be a useful allowance?

Extracting Profits from an Owner-Managed Business
NEW: How can an owner extract profits from a company?

Reasonable Excuse
NEW: What is reasonable when it comes to filing failures?

Missed last time's Web-update?

Nichola's SME tax W-update 7 June 2019


  • Company tax: What's New? June 2019
  • Reorganisations case study 6: POS buyout retiring shareholder
  • Blog: Trying to sign up to Making Tax Digital for VAT
  • Virtual Tax Partner © Toolkit 
  • UT overrules FTT on profit adjustments
  • and much more..

Catch up with last month in tax 

May 2019: the month in summary
NEW: a summary of the newswires for the last month

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