The European Court of Justice (ECJ) has upheld Amazon's appeal against the European Commission's (EC) ruling that an Amazon royalty pricing arrangement agreed with the Luxembourg tax authorities was overstated. The EC had held that the reduction in profits amounted to receiving the equivalent of €250 million of State Aid.
SME Tax News
In John Douglas Wardle v HMRC [2021] TC08105, the First Tier Tribunal (FTT) dismissed an appeal against HMRC closure notices denying Entrepreneurs’ Relief as pre-trading activities were insufficient to render the partnership disposal the disposal of a business.
In Michael and Anthea Mullane v HMRC [2021] TC08100, the First Tier Tribunal (FTT) dismissed an appeal against HMRC closure notices denying Multiple Dwellings Relief (MDR) on the purchase of a property with an annexe. The cooking facilities were of insufficient quality to allow the annexe to be occupied as a separate dwelling.
The Office for Tax Simplification (OTS) has published ‘Simplifying practical, technical and administrative issues’, its second report on Capital Gains Tax (CGT). It recommends extensions to certain reliefs and a new 60-day deadline for paying and reporting CGT on residential property sales.
In Derek Storey v HMRC [2021] TC08090, the First Tier Tribunal (FTT) denied the taxpayer’s claims to deduct employment-related expenses owing to a lack of evidence to support them.
In Nael Khatoun v HMRC [2021] TC08085, the First Tier Tribunal (FTT) found that the purchase of a residential property with access to a communal garden was subject to residential rates of Stamp Duty Land Tax (SDLT) and not mixed-use rates.
The Department for Environment, Food and Rural Affairs (DEFRA) has published a consultation entitled 'Direct Payments to farmers: Lump sum exit scheme and delinked payments in England'.
HMRC's latest Trusts and Estates newsletter contains some useful information. Here is our enhanced version.
Hello
The Supreme Court published its decision in the Tooth discovery case this week. The key issue in the case was whether the act of putting the right figures in the wrong place of a tax return could be regarded as making a deliberate error. Making a deliberate error potentially exposes a taxpayer to a 20-year assessment window.
HMRC have issued their Agent Update for May 2021. We have summarised the key content for you with links to our detailed guidance on the topics covered.