SME Tax News

Missed our SME Tax Web-updates in May? Here is a summary of the month.

In Fowler v HMRC [2020] UKSC22, the Supreme Court found that a diver was an employee for the purposes of a double tax treaty and so subject to UK tax on his income.

In HMRC v NCL Investments Limited, Smith & Williamson Corporate Services Limited [2020] EWCA Civ 663, the Court of Appeal dismissed HMRC’s appeal finding that the costs of issuing share options through an Employee Benefit Trust (EBT) were deductible.

HMRC have published new advisory fuel rates for company car drivers which apply from 1 June 2020. Following recent drops in oil prices all rates, except those for fully electric cars, have been reduced.


As COVID-19 lockdown measures are gradually relaxed and Brexit negotiations continue, now is the time to start planning for the future, whatever that holds.

In Mackay v Wesley [2020] EWHC 1215 (Ch), a Court of Appeal decision highlights the significant costs of being a trustee when tax planning goes wrong and a trustee finds themselves solely liable for the trust's tax liabilities.