In HMRC v Epaminodas Embiricos [2020] UKUT 0370, the Upper Tribunal (UT) confirmed that HMRC cannot issue a partial closure notice which does not quantify the amount of tax due.
SME Tax News
Hello
As we head towards 31st January, don’t forget to put in a Time to Pay agreement with HMRC if you are unable to settle your tax bill. We have updated our guides to ‘Reasonable excuse’ and ‘Insufficiency of funds’ this week. It is probably best to review these before the end of the month if it is likely that you or your clients are going to have any potential filing or late payment tax failure.
In Hadee Engineering Co Ltd v HMRC [2020] TC07969, the First Tier Tribunal (FTT) upheld the appeal in part for closure notices regarding R&D claim enquiries. In the main, the appellant failed to meet the qualifying criteria.
In Peter Kennedy v HMRC [2021] TC7987, the First Tier Tribunal (FTT) dismissed a claim for Entrepreneurs’ Relief by a shareholder who was not an employee or officer of the company for the year prior to the share disposals.
In Tim Norton Motor Services v HMRC [2020] TC7973, the fact that a Maserati and Ford GT40 had a Statutory Off-Road Notice (SORN) and management permission was required for any private use, were not sufficient as restrictions to prevent private use and a taxable car benefit applied.
HM Treasury has published ‘Small Brewers Relief (SBR): technical consultation’. The consultation calls for further industry input on technical issues surrounding the first and second-stage reviews.
In Cartref Care Home Ltd & Ors, R (on application of) v HMRC [2020] EWCA Civ 1744, the Court of Appeal refused permission to appeal against a judicial review that found that the imposition of the loan charge on outstanding loans did not breach the Human Rights Act 1998.
HMRC have concluded their consultation entitled 'Supporting veterans' transition into civilian life through employment' and released both comments and draft legislation for further consultation.
In HMRC v Andreas Rialas [2019] UKUT 0140, the Upper Tribunal (UT) dismissed an appeal by HMRC, finding the Transfer of Assets Abroad rules did not apply to dividend income as Mr Rialas was not the transferor, or sufficiently involved in the transfer, of shares acquired from his former business partner by his family trust.
Our 2020 Evil Quiz lived up to its reputation. Noone managed to answer all the questions correctly. To put you out of your misery, here are the answers. Our winner will be added later.