In Stephen Warshaw v HMRC [2019] TC08674 the FTT allowed an appeal against £1,158,916 of CGT: cumulative compounding preference shares were ordinary shares for Entrepreneurs' Relief.
SME Tax News
In Bryn Williams v HMRC [2019] TC06963 the FTT held that a taxi firm owner should have registered for VAT; he was not acting as an agent for his drivers when contracting with local authorities.
HMRC have amended VAT notice 700/22 to provide further guidance on the use of supplier statements, petty cash transactions and charity fundraising events.
In Hargreaves v HMRC [2019] TC07090 HMRC's long delay in raising an assessment on an £84m capital gain meant that there was no 'discovery' and it was invalid.
In Bank Mellat v Her Majesty’s Treasury [2019] EWCA Civ 449 the Court of Appeal explored the interaction of English law and foreign laws in terms of access to sensitive evidence.
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This time we are looking at shares, from share purchases to reorganisations.
In Vermilion Holdings Limited v HMRC [2019] TC07077, the First Tier Tribunal (FTT) found that share options granted to a director were not Employment-Related Securities. They were not issued by reason of his employment.
In Bostan Khan v HMRC [2018] TC0752, an individual who personally bought out controlling shareholders found that the subsequent purchase by his new company of his shares did not qualify for Capital Gains Tax (CGT) treatment. His subsequent attempt to claim that the transaction was a trade failed too.
We are happy to promote some exciting job vacacancies in tax for the amazing tax charities: TaxAid and Tax Help for Older People.
In Philip Hunt v HMRC [2018] TC02528, the First Tier Tribunal (FTT) decided that the Entrepreneurs’ Relief test for a percentage holding in a company’s ‘ordinary share capital’ should be measured by nominal value rather than the number of shares in issue.