HMRC have stepped up their investigations into the tax affairs of the football industry, tripling investigations of individual professional footballers and more than doubling its tax takings from investigations in 2019/2020.
SME Tax News
The government has published a consultation paper, 'Non-Contentious Probate Mandating online professional applications'. It proposes changing the non-contentious probate rules to make it mandatory for professional users, such as solicitors and other probate practitioners, to use the online process.
In Armstrong & Haire Ltd v HMRC [2020] TC7780, the First Tier Tribunal (FTT) refused a Corporation Tax deduction for goodwill amortisation. The pre-incorporation businesses had been carried on before April 2002.
In David Merchant and Sarah Gater v HMRC [2020] TC07783, the First Tier Tribunal (FTT) dismissed the appeal made by the taxpayers. It was found that the closure notice issued by HMRC was valid and that the annexe was not a separate dwelling for Stamp Duty Land Tax (SDLT) Multiple Dwellings Relief (MDR).
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This time we have a capital taxes round-up. We look at the options of those thousands of taxpayers who still have Employee Benefit Trust loans, we review some topical cases and we have new CPD.
In Ian Shiner & David Sheinman v HMRC [2020] TC7779, the First Tier Tribunal (FTT) disallowed interest on loans to members of a trading partnership. The loans were taken by the partners as investors and not the partnership and the interest paid was not wholly and exclusively for the partnership trade.
In BlueCrest Capital Management Cayman Limited (& others) v HMRC [2020] TC 07782, the First Tier Tribunal (FTT) agreed that the sale of occupational income rules could apply to charge Income Tax on partnership capital contributions.
In Oisin Fanning v HMRC [2020] TC07776, the First Tier Tribunal (FTT) found that HMRC's discovery assessment was validly issued. The assessment represented a 5% SDLT charge on the purchase price of a £5 million property in London. Mr Fanning (the taxpayer) had used an avoidance scheme involving a sub-sale relief and grant of options.
The House of Commons’ Public Accounts Committee (PAC) has published its report on the 'Management of Tax Reliefs'. It concludes that HMRC and HM Treasury need to improve their reporting on the cost, beneficiaries and impact of tax reliefs so that parliament can scrutinize the value for money of these benefits.
Missed our SME Tax Web-updates in July? Here is a summary of the month.