Hello,
This week, we have news of incorrect SA302 tax calculations. We also take a look at a recent First Tier Tribunal (FTT) tax hearing, in which Artificial Intelligence (AI) played a part, but did not help the taxpayer’s appeal.
In 2023, we reported the FTT’s decision in Felicity Harber v HMRC. That case was notable because the taxpayer had relied on AI to form a penalty appeal, but unfortunately, the cases it cited were fictitious.
On a similar theme, this week we examine the newly published decision in Bodrul Zzaman v HMRC. Here, the taxpayer relied on AI to prepare his statement of case when appealing a High-Income Child Benefit Charge discovery assessment.
While the case law the AI tool gave was not made up on this occasion, the cases generated did not provide authorities for the arguments made by the taxpayer.
In response, the FTT judge went on to comment on the use of AI and how to reduce the dangers of relying on AI tools, including using human checks to confirm that assertions a tool generates are accurate.
In other news, the Chartered Institute of Taxation (CIOT) are highlighting errors in some 2024-25 SA302 tax calculations relating to Class 2 National Insurance contributions; something to watch out for.
Do also note that new advisory fuel rates, applying from 1 June 2025, have been published.
More news, cases, and updates below.
The Ross Martin Tax Team
Online PRACTICAL tax resources for accountants and tax advisers BY accountants and tax advisers.
Quick News
Advisory fuel rates from 1 June 2025
HMRC have published new advisory fuel rates for company car drivers that apply from 1 June 2025.
HMRC issuing incorrect SA302 calculations
The Chartered Institute of Taxation (CIOT) has highlighted issues with HMRC's 2024-25 Self Assessment calculations. Several individuals have reported that Class 2 National Insurance Contributions (NICs) are being incorrectly included on SA302 tax calculations.
Increase in SEIS investments but decreases in other investor reliefs
HMRC have released statistics showing an increase in the number and amount of investments made under the Seed Enterprise Investment Scheme (SEIS). The statistics also show decreases in Enterprise Investment Scheme (EIS) and Venture Capital Trust (VCT) scheme investments.
One-to-many letters: Tracker
HMRC's latest one-to-many letter is being sent to companies whose financial statements show loans to directors and employees of more than £10,000 each, reminding them of the need to report beneficial loans on forms P11D and P11D(b) by 6 July 2025 for 2024-25.
Tax Cases
AI fails to help taxpayer in HICBC appeal
In Bodrul Zzaman v HMRC [2025] TC09520, the First Tier Tribunal (FTT) found that a taxpayer’s use of Artificial Intelligence (AI) to write his statement of case did not provide grounds to allow his High-Income Child Benefit Charge appeal. The case law cited failed to provide authorities for the arguments made.
Successful appeal against R&D discovery assessment
In Realbuzz Group Ltd v HMRC [2025] TC09502, the First Tier Tribunal (FTT) allowed an appeal against a discovery assessment raised in respect of a Research & Development (R&D) claim. At the end of the normal enquiry window, the hypothetical HMRC officer should reasonably have been aware of the excessive R&D claim, which resulted in an insufficiency in tax.
ToAA rules applied to rent-free house occupation
In Anne Concepta Moran v HMRC [2025] TC09521, the First Tier Tribunal (FTT) found that a taxpayer was liable to Income Tax under the Transfer of Assets Abroad (ToAA) legislation due to her rent-free occupation of a house settled in an offshore trust by her late husband.
Orthodontic aligners were VAT-exempt
In Align Technology Switzerland GmbH & Anor v HMRC [2025] TC09499, the First Tier Tribunal (FTT) found that orthodontic aligners were VAT-exempt dental prostheses.
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