Hello
We have a new Agent Update from HMRC, together with a subscriber special on Employment-Related Securities. We have been testing the new GOV.UK Chat. As always we have a broad selection of tax case summaries and other news and updates. Have you heard of PISCES?
As part of an attempt to encourage investment in private companies, the government is introducing a new trading mechanism for unlisted private company shares. It goes by the name of the Private Intermittent Securities and Capital Exchange System (PISCES). This is a radical move and not without potential problems, but regulation is set to be lighter than for listed shares. It's well worth reading up on this and following developments, see Editor's choice.
Last night, I gave an informal talk to a group of non-accountants on 'a tax adviser's tax on the Autumn Budget'. Everyone was engaged and interested as my thoughts were clearly radically different to those of the popular press. As we continue to update our tax guides, post Autumn Budget, I just checked out the 'hits'. Guess which budget announcement has received the most hits?
Double Cab pick-ups! Who would have guessed!
See you next week, when we have news of a Christmas special.
Nichola and the Team
Your Virtual Tax Partner®: online PRACTICAL support for accountants, tax advisers BY accountants and tax advisers.
Quick News
Testing testing: GOV.UK's AI powered Chat
The Government has launched a trial version of its new AI powered chat. It is early days for the GOV.UK Chat. As AI Large Language Models (LLMs) are known to hallucinate, i.e. make up stuff, it should be used with extreme caution. Initial tests show it's not too bad on that front.
Visual effects costs defined
HMRC have published the summary of responses for their 'Consultation on additional tax relief for visual effects costs'. The consultation outlined the scope of visual effects and how the additional tax relief will work.
Rising rates and shrinking safety nets for NLW
In light of the substantial increase in the National Living Wage (NLW) and National Minimum Wage (NMW) rates From April 25, it is crucial for employers to understand the implications and risks. Jeni Morris, Head of EY National Minimum Wage Technical Team, explores the key risk areas and identifies who might be most vulnerable.
Agent Update: November 2024
HMRC have published their Agent Update for November 2024. We have summarised the key content with links to our detailed guidance on the topics covered, including changes to CIS on traffic management works, updates to payrolling of benefits, and common errors in claiming double tax relief.
Advisory fuel rates from 1 December 2024
HMRC have published new advisory fuel rates for company car drivers from 1 December 2024.
Tax Cases
Accounting period not covered by Advance Pricing Arrangement
In Refinitiv Ltd & Ors v HMRC [2024] EWCA Civ 1412, the Court of Appeal (CoA) held that Diverted Profits Tax (DPT) notices were correctly issued and were not inconsistent with an Advance Pricing Agreement (APA), as the five-year term to which the APA applied had expired.
FTT rules loan had an unallowable purpose
In Syngenta Holdings Limited (SHL) v HMRC [2024] TC0934, the First Tier Tribunal (FTT) ruled that SHL's decision to enter into the loan was driven by the wider group strategy to obtain a tax advantage. The main purpose of securing this tax advantage rendered the loan to have an unallowable purpose.
SDLT sub-sale tactic increased tax liability
In Mr and Mrs Murphy v HMRC [2024] TC9324, the FTT calculated that the chargeable consideration created under a failed Stamp Duty Land Tax (SDLT) sub-sale scheme was substantially greater than the chargeable consideration on the actual sales proceeds of the property.
Coronavirus support calculated on 'unpaid' wages
In Sinter Site Services Ltd v HMRC [2024] TC09343, the First Tier Tribunal (FTT) found that a family company's Coronavirus support claims for its various family members employees were calculated on future unpaid earnings and were excessive.
Editor's Choice (subscribers)
Employment-Related Securities (ERS): What's new 2024/25
HMRC have published a couple of their ERS bulletins of late, and we have combined their updates with several extras to provide this subscriber special 'What’s New'.
Private Intermittent Securities and Capital Exchange System
What is the Private Intermittent Securities and Capital Exchange System (PISCES)?
Ten top planning tips for IHT
The Budget recently made a number of changes to Inheritance Tax (IHT). What are the ten top IHT planning tips to consider?
Autumn Budget 2024 Zone
Check our Budget coverage with links to our Subscriber special updates and Client Briefings.
Guides & Updates
Self-employed
Tax rules for different trades, professions and vocations
Self Assessment season: How are different types of businesses taxed? What special rules apply to different types of business income and expenses? What about VAT? We summarise the different rules for taxing income and expenses of a large selection of different trades, professions and vocations.
Double Cab Hic-Ups
Rules change from next April: Double cab pick-up vehicles with a payload of one tonne or more will no longer be treated as goods vehicles but will instead be cars for BIK purposes.
Partnerships
Partnerships: Capital Gains Tax
How does Capital Gains Tax (CGT) work for partners and partnerships? What is HMRC’s Statement of Practice D12? How are transactions between partners treated? What if the partners are connected persons for CGT?
Directors & Companies
Creative Industries: Audio-Visual Expenditure Credit (AVEC) & Video Games Expenditure Credit (VGEC)
Audio-Visual Expenditure Credit (AVEC) will replace Film Tax Relief (FTR), High-End TV Tax Relief (HETR), Animation Tax Relief (ATR), and Children’s TV Tax Relief (CTR). Video Games Expenditure Credit (VGEC) will replace Video Games Relief (VGTR).
Loans to participators (Close Company toolkit)
What is the Corporation Tax treatment when a close company makes a loan to a participator (director-shareholder)? How do the 'bed and breakfasting' rules work? What are the concerns with MBOs?
Research & Development Tax Reliefs
What is R&D Relief? How does it work? Why does the size of the company matter? What is sub-contracted R&D? How do I write an R&D Report?
Overseas & Residence
Transfer of Assets Abroad (ToAA)
What are the ToAA rules? When do they apply? How is the tax charge calculated? Is there any defence against the rules?
Employers
EMI: Enterprise Management Incentive Scheme
What is the Enterprise Management Incentive (EMI) scheme? What's the difference between EMI and an unapproved share scheme?
Employers' Autumn Budget 2024 (Subscriber Update)
UPDATE: we look at winners and losers from the changes to National Insurance rates, changes to benefits and expenses and actions on umbrella companies.
Private Client & Estate Planning
How to close a UK trust
What are the tax implications of winding up a trust? What do I need to do as a trustee to wind up a trust? Why wind up a trust?
Business Asset Disposal Relief (Entrepreneurs' Relief): Disposal of a business
Entrepreneurs' Relief (ER) was renamed Business Asset Disposal Relief (BADR) by Finance Act 2020. When does BADR apply? What is the rate of BADR? How do you claim BADR? What BADR case law is there?
Investors' Relief
What is Investors' Relief? How does it differ from Business Asset Disposal Relief? Which disposals qualify? What are the conditions?
Land & Property
Abolition of the FHL regime: Briefing
HMRC have published draft legislation and related notes detailing how the abolition of the Furnished Holiday Letting (FHL) rules in April 2025 will operate. We consider the practical impact of losing the FHL rules and provide some essential planning points.
VAT News & Cases
Deposit Return Scheme: Drink containers
UPDATE: The Deposit Return Scheme (DRS) is an environmentally ambitious scheme for single-use drink containers. It will now not be introduced until October 2027. How will it operate for VAT purposes?
Partial exemption & input VAT
How do you calculate the amount of input tax you can recover under the VAT partial exemption rules? What are the de minimis rules?
Tax Tools & Calculators
Tax tools & calculators
UPDATE: 2024/25 versions available now. We have a suite of useful tax tools that help agents, business owners and sole traders calculate their taxes.
Calendar of tax deadlines and new tax measures
UPDATE: This is a freeview 'At a glance' rolling calendar of common recurring tax deadlines, new tax measures and other tax-significant events.
CPD
CPD for lunch: Byte-sized chunks of lunchtime CPD (free for our Subscribers)
- CPD: Income Tax and Trusts
- Free Study Skills Session - Preparing for Your Tax Exams
- CPD: Change of basis periods: Transitional rules 2023-24 Returns
- How to run the most tax-efficient business 2024/25.
- Purchase of Own Shares: all the details.
- Anti-money Laundering Update and Firm-Wide Risk Assessment ...More...
Tax Queries?
UK Agent for registration of Overseas Entities
Do you require assistance in the registration and verification of an overseas entity that owns UK land or property?
Virtual Tax Partner© Support
Have a tax query? Need a second option? Open a ticket and ask a question. A team of tax experts with a wide range of expertise: covering direct and indirect tax, as well as accounting, R&D claims, reorganisations and much more.
Missed the Last Tax Update?
Ross Martin Tax: SME Tax News 21 November 2024
- Request overlap profits by 31 December 2024
- NICs: Top up before April 2025
- The Loan Charge: What now?
- Consultation on new ways to tackle non-compliance
- Reduction in HMRC's interest rate
- Confirm HMRC agent codes by 6 December
- CGT: no TTP, no reasonable excuse ...More
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