HMRC have released two more opinions in their favour from the GAAR advisory panel (GAP) in quick succession; about disguised remuneration, loans to participators, and employee rewards using second hand bonds and gilt options.
SME Tax News
HM Treasury have opened a new call for evidence on Social Investment Tax Relief as take up has been poor and the the relief is currently due to end in 2021.
In Hopscotch Limited v HMRC [2019] TC07127 the FTT found that the redevelopment of a single house in order to sell it was not a property development trade; no ATED relief was due.
In Raymond Tooth v HMRC [2019] EWCA 826 the Court of Appeal confirmed that HMRC's delay in raising a discovery assessment had rendered it invalid. The decision was subsequently appealed by HMRC. The Supreme Court under different reasoning ruled that there was no discovery.
In Mr Douglas Shanks v HMRC [2019] TC07118 the FTT cancelled penalties for inaccuracies but disallowed partnership losses; they were not substantiated and from a different trade to the profits against which they were being offset.
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We are taking a break from reporting cases this week, as we have picked out quite a diverse range of news items and we also have a bumper capital taxes update.
The government has opened a consultation on the UK's approach to carbon pricing after Brexit, to consider various options to enable the UK continue to meet its carbon reduction targets after we leave the EU.
The Office of Tax Simplification (OTS) has published a report ‘Simplifying everyday tax for smaller business’, It suggests that there is much the government can do to make life easier for small and micro business.
The Department of Business, Energy and Industrial Strategy (BEIS) has opened a consultation on ‘Corporate transparency and register reform’. This considers wide ranging and radical reforms.
Some employers have been applying Scottish PAYE codes to Welsh taxpayers in error. The Welsh Assembly have blamed this error on HMRC. HMRC's Jim Harra has responded to say that HMRC is not at fault.