HMRC have published their Employer Bulletin for April 2017. We summarise the key content for you, with links to our detailed guidance on the topics covered.
SME Tax News
HMRC have published responses to their consultations ‘Tackling the hidden economy: Sanctions’ and ‘Tackling the hidden economy: Conditionality’.
HMRC's consultation, ‘Making Tax Digital sanctions for late submission and late payment' closed on 11 June 2017. Responses are anticipated shortly.
The Government have published a call for evidence on proposals for ‘A register of beneficial owners of overseas companies and other legal entities’.
In MVM Magyar Villamos Muvet Zrt. V Nemzeti Ado-es Vamhivvatal Fellebbviteli Igazgatosag (Case C-28/16) a holding company was unable to reclaim input VAT on its management activities as it was providing its services free of charge to its subsidiaries.
In Smith and Nephew Overseas (and 2 others) v HMRC [2017] TC05644 accounting exchange losses arising from a change in the group’s functional currency were allowed for tax.
In Desmond Higgins v HMRC [2017] TC 05724 the period of ownership of an off-plan apartment was found to have started for PRR purposes only once the property was complete.
HMRC have published a response to their consultation ‘Partnership taxation: proposals to clarify tax treatment’.
In BCM Cayman LP and various Bluecrest entities v HMRC, taxpayers were only partially successful in forcing HMRC to issue closure notices into long running and complex tax enquiries concerning the tax arrangements of hedgefunds.
In Stuart Gulliver v HMRC [2017] TC05712 an application for closure notice in order to block a sch 36 information notice failed. The fact that HMRC had agreed a taxpayer's change of domicile in the past did not mean that they could not revisit the issue in a later year and ask more questions.