A profit extraction tax avoidance scheme involving gold bullion, which aimed to beat the Disguised Remuneration rules and was first identified by HMRC back in 2016 in its Spotlight 30, has been tested by the First Tier Tax Tribunal (FTT). It seemed a surprising case to appeal, as the appellant company and their adviser had ceased trading. The FTT found that it did not work.
SME Tax News
HMRC have issued two one-to-many letters covering those they believe are trading and have taxable income connected with online marketplaces or online content creation.
In Shivsagar Enterprises Ltd v HMRC [2022] TC08681, the First Tier Tribunal (FTT) dismissed an appeal against penalties for the late filing of a soft drinks industry levy return. The taxpayer did not have a reasonable excuse for their failure to file on time, and even if they did they did not remedy the failure without unreasonable delay.
The government has published a new consultation, 'R&D Tax Reliefs Review: Consultation on a single scheme'. Following the steps to equalise the relief provided by the two existing regimes, the government is seeking views on the schemes being merged into one.
In Hoopla Animation Limited v HMRC [2023] TC08683, the First Tier Tribunal (FTT) found that a subcontracting company's involvement in the allocation of funds raised under an EIS share subscription was a disqualifying arrangement. As a result, EIS relief was blocked despite the subcontracting being on commercial terms.
In Nikola Polakova v HMRC [2023] TC8690, the First Tier Tribunal (FTT) found that 29,800 cigarettes brought to the UK were not for personal use. While a late appeal was considered, it was struck out. The penalties based on deliberate behaviour were upheld.
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As we approach the deadline for filing Self Assessment tax returns, we have put together a list of ‘Top tips’ covering some of the oddities that we have picked up from your queries. For those who have filed all their returns and are looking forward to the end of the tax year, we have a year-end planning guide for owner-managed businesses.
A summary of our top tips for dealing with last-minute tax returns.
Finance Bill 2023 received Royal Assent on 10 January 2023 and became Finance Act 2023. It is the first Finance Act to be approved by King Charles III.
In Nilebond Limited v HMRC [2022] TC08676 the First Tier Tribunal (FTT) dismissed an appeal against a pension scheme's unauthorised payment charge in respect of an unauthorised loan made by the scheme to the sponsoring employer. The loan should have been secured when paid and that condition was not met.