In David Briggs & Others v HMRC [2019] TC07166 the FTT held that a change in a right to earnout consideration from loan notes to cash was a disposal of that right and triggered the gain deferred on the original disposal.
SME Tax News
HMRC have completed their review of cases where a failure to notify penalty was issued to taxpayers who did not register for the High Income Child Benefit Charge, repaying £1.8m in penalties.
Hello
This week we have some amazing announcements to make. We also have free CPD in the form of our Company Tax update and worrying news about loan charge settlements.
In HMRC v Total E&P North Sea UK Limited and another [2019] UKUT TC133 the Upper Tribunal overruled the FTT; the method used by the taxpayers to apportion their company profits went beyond what was just and reasonable. The Court of Appeal (CA) has found in favour of the taxpayers and agreed with the FTT findings.
With months to go for all ongoing disguised remuneration (DR) settlements to be completed we doubt HMRC has the resource to cope. It's not looking good.
The deadline for reporting details of outstanding disguised remuneration loans to HMRC is 1 October 2019. The online tool for making these reports is now available; a government gateway account is required plus full details of all loans.
Missed the news for April 2019? Here is a summary of the month.
Missed our SME Tax Web-updates in May? Here is a summary of the month.
- Nichola's SME Tax W-update 31 May 2019
- CIS fail: no evidence of 33 penalty assessments
- All change for Corporate non-resident landlords with UK property gains or income
- Advisory fuel rates from 1 June 2019
- The Role of Professional Bodies in the regulation of tax agents
- No place in CIOT for tax advisers who promote avoidance