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Hello,
The government’s extremely tardy response to its 2018 consultation on Employment Status reveals that it’s apparently too difficult to legislate to create a statutory employment test. A great opportunity lost, in my humble opinion.
The Office of Tax Simplification (OTS) has published a scoping document examining the emerging trends and tax implications of hybrid and distance working.
In HMRC v BlackRock Holdco 5, LLC [2022] UKUT 00199, the Upper Tribunal (UT) held that loan relationship debits claimed as part of an intra-group financing arrangement were wholly attributable to the unallowable purpose of the lending and not the commercial purpose and were denied.
The General Anti-Abuse Rule (GAAR) Panel has issued its opinion on the use of group loans to avoid the s.455 loan charge, finding that although there was a gap in the legislation, its exploitation was not enough to apply the GAAR and the steps remained a reasonable course of action for the group.
HMRC have opened a consultation ‘Improving the data HMRC collects from its customers’, to explore options for improving the range of data collected directly from taxpayers. Proposals include measures requiring director/shareholders of close companies to separately identify, on their tax return, the dividends they receive from their company.
After a six-month delay, HMRC has confirmed that declaring a capital gain on the disposal of a UK residential property under Self Assessment does not remove the requirement to file a 60-day property disposal return.
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