I was interested to see that HMRC has decided to put Scottish team Rangers FC into liquidation.

It owes around £100 million in tax and penalties so this takes it to the top of the leaque of HMRC's football debtors. By using liquidation HMRC is hoping to pursue the club's ex-management who amongst other things used an EBT scheme and offshore cash scheme to apparently disguise contractural payments to some players.

Researching a tax case on Baili (the free online case reporter) I stumbled across a non-tax case which serves as a cautionary tale for retiring company directors. Many directors are keen, in the current economic climate, to cut costs whenever possible and this tends to mean cutting corners and often ignoring the formalities of the Companies Act. One such individual and his wife were sued by his ex-company's liquidators.

We also have new guidance from HMRC on "Pre-loved" Olympic Torches, updates on car fuel, EMI and SEIS and the various U-turns post Budget - what a waste of time and energy.

Those running smaller practices will be pleased to hear that HMRC has also decided to back down on plans to introduce tighter iXBRL tagging requirements next year.

Scroll on down for the updates.

Best wishes


Nichola Ross Martin FCA
Tax Director

Your online Virtual Tax Partner®: practical support for accountants, tax advisers and their clients


HMRC force Rangers into liquidation
The Scottish team's EBT scheme backfires and unpaid debts leads HMRC back to its management.

Case report: share repurchase action by liquidator
Directors' essential reading on retirement and share purchase. This is why it pays to take proper advice and follow Companies Act formalities.

Essential reading:

Advisory fuel rates (company car drivers)
New rates from 1 June 2012.

EMI: new limits from 16 June 2012
The limit on qualifying Enterprise Management Incentives (EMI) options rises from £120,000 to £250,000 on 16 June 2012.

EIS or SEIS: advanced assurance from HMRC
A new form to check out your qualifying criteria.

VAT: update
Summary of latest U-turns post Budget.

Charity tax relief - another U-turn
No cap on unlimited tax relief on charitable giving.

More U-turns: XBRL tagging
HMRC shelves plans for enhanced tagging from next year.

Olympic Torch for sale
Quick guide: tax on the disposal of chattels.

Student Loans
HMRC how to report under SA guide.

Consultation watch

Disincorporation Relief
NEW: consultation explores whether there is a demand for a new measure that might reduce CGT liabilities when a business changes its legal form.

The Taxation of Controlling Persons
NEW: consultation which looks at ensuring that individuals who are managing organisations, whether in the public or private sector, cannot operate via service companies. The engager must deduct PAYE.


IT consultant's offshore arrangements lead to jail
Basic scheme to divert income offshore is just fraud.

E-marketplaces campaign
HMRC's latest campaign targets online traders: notify by 14 June 2012.

Guides and updates


Use of home as office calculator
UPDATE: maximise tax relief on the costs of working at home.

Subscribers only:

Extracting profits (self-employed)
UPDATE: Can you charge yourself rent? Should a spouse be an employee or a partner? What flat rate allowances are worth claiming?

Tax-efficient extraction of profits
UPDATE: 2012/13 update of this toolkit for company owners.

Is it worth restructuring to save tax?
UPDATE: a quick guide reviewing what business combinations are popular in 2012.

Accommodation costs (self-employed)
NEW: a mini-guide with a case comparison of when tax relief can be obtained on a flat rental

Anti-avoidance guides for SME owners

The Settlement provisions
Rules are designed to prevent individuals from avoiding tax by artificially diverting their income.

Transactions in securities
There are different provisions for income tax and corporation tax. For the SME owner/adviser it is the income tax rules that potentially cause the greatest problem.

Employment Related Securities
These rules will affect any share award made to an employee, unless part of an approved scheme or EMI option plan.

Disguised remuneration rules
Part 7A of ITEPA 2003 is new; it sets out rules designed to tackle situations where remuneration is disguised as loans.

Sale of occupational income
These anti-avoidance measures apply to the sale of an individual's income from a profession or vocation but not of a trade.

Transfer of income streams
These measures affect the transfer of an income stream, without the transfer of an underlying asset.


ABC or alphabet shares: family companies
Looking at the tax consequences of creating new share classes.

ABC or alphabet shares: directors & employees
Looking at the tax consequences of creating new share classes for employees.

Running an LLP in tandem with a company
UPDATE: lots of pluses and minuses for professional practices.

PAYE late payment penalties buster
Top tips for employers: you need to change your behaviour - but not quite in the way that HMRC had planned.

Updates from last time

Close Investment Holding Companies
UPDATE: two recent reports from the Tribunals indicate how easy it is to overlook the rules.

Employment status checklist
UPDATE: new cases add some dimension to the existing tests.

Capital Gains Tax: Entrepreneurs' Relief
UPDATE: comparing the disposal of part of a business and its assets.

Tax Cases Update

CGT PRR relief denied for a second home flip
An election to flip properties fails. The second "home" must qualify as a residence even if the election only lasts for a week.

Employee benefits : once a car always a car?
Can a Land Rover stop being a car given that it was constructed as a car? Maybe.

PAYE regs' avoidance scheme fails
The plan depended on the operation of the PAYE regulations to prevent double taxation but lead to penalties for negligence.

Actor allowed deduction for 9 months of accommodation
Renting lodgings near a theatre were wholly and exclusively incurred.

Property letting not a business for CGT
No business asset relief available for assets used in ordinary letting confirmed.

Eclipse Film Partners No 35 LLP
A business, but no trade? A film partnership is blocked from claiming loss relief: its activities did not amount to trading.

Recent updates

Furnished Holiday Letting
Including examples on Averaging and Period of Grace reliefs.

Fees and subscriptions (professional bodies)
UPDATED: no tax deduction against employment income if not on HMRC's list.

Retirement: a purchase of own shares
A menu and summary.

Joint property: legal v beneficial ownership
This guide explains the differences, looks at transfer of beneficial ownership, issues for spouses and Declarations of Trust.

Capital reduction with a purchase of own shares
This is a very complicated combination, so we have created this checklist.

Capital reduction: tax treatment
This guide examines the position where a capital reduction is used and trading is ongoing.

Employment status: partners
This guide considers a problem for some professional firms.

Business Property Relief: holding companies
UPDATE: following recent queries we have included further examples to deal with mixed trading groups.

Interest: paid on loans from directors
NEW: mini-guide. Is interest paid gross or net? At what rate? Tax relief when irrecoverable.

Valuation (of goodwill) on incorporation
UPDATE: new examples for small & lifestyle businesses.



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