SME Tax News

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.

In Anne Concepta Moran v HMRC [2025] TC09521, the First Tier Tribunal (FTT) found that a taxpayer was liable to Income Tax under the Transfer of Assets Abroad (ToAA) legislation due to her rent-free occupation of a house settled in an offshore trust by her late husband.

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.

In Realbuzz Group Ltd v HMRC [2025] TC09502, the First Tier Tribunal (FTT) allowed an appeal against a discovery assessment raised in respect of a Research & Development (R&D) claim. At the end of the normal enquiry window, the hypothetical HMRC officer should reasonably have been aware of the excessive R&D claim, which resulted in an insufficiency in tax.

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.

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.   

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.

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.