In S&L Barnes Limited v HMRC [2023] TC08697, the First Tier Tribunal (FTT) applied the tests from Ready Mixed Concrete and found that Stuart Barnes provided his rugby punditry services to Sky as part of his own business, not as an employee.
SME Tax News
In Martin Clarke West v HMRC [2023] TC08705, the First Tier Tribunal (FTT) found that a late appeal against HMRC assessments, closure notices and penalties was not permitted. There was no good reason for the serious and significant delays, which exceeded 1,000 days.
HMRC's latest Employment-Related Securities Bulletins for January and February 2023 contain some useful information. Here are our enhanced versions.
In Nicholas John Hall and Christopher Valentine Lopez as Trustees of the Carolina Raboni Estate v HMRC [2022] TC08691, the First Tier Tribunal (FTT) agreed that there was no Interest In Possession (IIP) in a house where the estate assets, apart from the house, were insufficient to pay the Inheritance Tax (IHT).
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HMRC have just published a new Agent update and, amongst other things, this includes new guidance on the Transfer of Assets Abroad (TOAA) provisions. It is only speculation on our part, but these anti-avoidance rules might have been one reason why a government minister is reported to have made a seven figure tax settlement with HMRC this week. His visable tax planning as shown on Companies House was to place his shares in a UK company into an offshore trust. Either he fell under the TOAA or the settlor interested trust rules, we guess, as both prevent individuals avoiding UK taxes.
HMRC have issued their Agent Update for January 2023. We have summarised the key content for you with links to our detailed guidance on the topics covered.
This week's competition asks you to come up with an amusing title or caption for one of our case write-ups.
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.
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.