In HMRC v Mr Neil and Mrs Sharon Pickles [2022] UKUT00253, the Upper Tribunal (UT) found a distribution arose when an asset was transferred in excess of its market value on incorporation. The value of the distribution was the benefit received by the taxpayer over and above the market value of the asset transferred.
SME Tax News
In their responses to HMRC consultation on Cryptasset taxation, both the Institute of Chartered Accountants of England and Wales (ICAEW) and Chartered Institute of Taxation (CIOT) call for total re-think on the taxation of cryptoassets in the UK.
In The Quentin Skinner 2015 Settlements v HMRC [2022] EWCA Civ 1222, the Court of Appeal (CoA) found that Entrepreneurs’ Relief was due on the sale of shares by a trust. The individual did not have to be a qualifying beneficiary throughout the one-year period when the personal company condition was met, only at the time of disposal.
The Institute of Chartered Accountants in England and Wales (ICAEW) has published its response to the proposed changes to Research and Development (R&D) tax relief, in which it makes a number of observations and recommendations.
The government's new Energy Bill Relief scheme provided help for business customers in Great Britain from 1 October 2022 to 31 March 2023. This is replaced with the Energy Bills Discount Scheme from 1 April 2023 until 31 March 2024.
In Anthony Calcutt v HMRC [2022] TC08582, the First Tier Tribunal (FTT) a self-employed taxpayer and landlord failed to provide sufficient information to displace tax assessments and suffered 60% tax penalties as a result.
The Chancellor Kwasi Kwarteng is expected to deliver a mini-Budget on 23 September 2022.
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As the country is in a period of national mourning we have a very short news update this week, with mainly freeview content for you.
In Raj Sehgal and Sanjeev Mehan v HMRC [2022] TC 8581, the First Tier Tribunal (FTT) found that arrangements which resulted in a non-UK entity settling a UK-based indemnity did not represent a taxable remittance for the taxpayers.
In Gallaher Limited v HMRC (Case C-707/20), the Advocate General to the CJEU decided that the UK group asset transfer rules were justified in restricting the EU Freedom of Establishment and the lack of ability to defer the tax payment was not disproportionate given that consideration was received.