In Bodrul Zzaman v HMRC [2025] TC09520, the First Tier Tribunal (FTT) found that a taxpayer’s use of Artificial Intelligence (AI) to write his statement of case did not provide grounds to allow his High-Income Child Benefit Charge appeal. The case law cited failed to provide authorities for the arguments made.
Hello,
This week’s highlights include the May 2025 Agent Update, HMRC issuing Stop Notices to an individual for the first time, and a report from the National Audit Office (NAO) on collecting the right tax from wealthy individuals.
HMRC have published their Agent Update for May 2025. We have summarised the key content with links to our detailed guidance on the topics covered. This month's update includes changes to Corporation Tax reminders, HMRC beginning to issue 2024-25 Simple Assessment letters and a new compliance check guidance tool.
In a bid to support the government's plan to close the tax gap, HMRC have issued their first Stop Notice to an individual. Paul Baxendale-Walker, a struck-off solicitor best known for his involvement in the Rangers Football Club tax avoidance case, is the first individual to be issued with a Stop Notice.
In Denise Howarth v HMRC [2025] TC09508, the First Tier Tribunal (FTT) found that a taxpayer who had failed to complete the final step to submit her tax return had a reasonable excuse for not submitting on time.
The National Audit Office's report, 'Collecting the right tax from wealthy individuals', warns that the levels of tax evasion and avoidance by Britain's rich may be much higher than HMRC previously thought. The complexity of their affairs allows for greater opportunities for dishonesty, the report concluded.
Hello,
In what has been a relatively quiet week for tax news, we explore the latest cases on trading loss relief, the novation of directors' loans, and the VAT treatment of assessments within an online maths learning product. We also look at HMRC’s most recent one-to-many letters.
In Nicholas Powell v HMRC [2025] TC09518, the First Tier Tribunal (FTT) found that an Income Tax charge arose on the novation of a director’s loan account from one company to its parent. Under the novation deed, a loan to a participator had been released.
In Charlotte MacDonald v HMRC [2025] TC09504, the First Tier Tribunal (FTT) found that sideways loss relief could not be claimed in respect of an annual 'woodland shoot' on an estate. The activities were not carried on with a view to the realisation of profits.
In Raymond and Diana Eyre v HMRC [2025] TC09498, the First Tier Tribunal (FTT) found that a couple who purchased, renovated and disposed of a property for £27 million were not doing so in the 'nature of trade'. In addition, they were entitled to claim Private Residence Relief.
