In Mabbutt v HMRC [2017] UKUT 0289 the Upper Tribunal (UT) concluded that a drafting error on a closure notice was not enough to invalidate it. This saved HMRC £653,000.
SME Tax News
HMRC has recorded a message on its phonelines to reassure taxpayers that the EU referendum result of Brexit heralds no immediate changes to the UK's tax system.
In Alpine Contract Services v HMRC [2016] TC05148 a director's actions led to penalties for deliberate behaviour. The FTT's interpretation of the term 'potential lost revenue' created a windfall for HMRC.
In HMRC v Apollo Fuels Limited [2016] EWCA Civ 157, the Court of Appeal has ruled against HMRC confirming that no car benefit arose to employees leasing cars from their employer at market value.
In Tottenham Hotspur Limited v HMRC [2016] UKFTT TC05143 the First Tier Tribunal (FTT) found that payments to players were termination payments and not subject to NIC.
In Mr Ignacius Fessal v HMRC [2015] TC04287 a barrister was successful in arguing that the European Convention on Human Rights (ECHR) prevented HMRC from denying an overpayment relief claim when tax was double charged following a change of basis of taxation.
HMRC have published their Employer Bulletin for June 2016. We summarise the key content for you, with links to our detailed guidance on the topics covered.
HMRC has kept several of its tax campaigns, or disclosure opportunities open. Any clients who might have undeclared liabilities in these areas should be encouraged to make disclosures to HMRC sooner rather than later to minimise penalties, interest and the pain of a formal investigation.
In X-Wind Power Limited v HMRC [2016] investors in the company lost out on tax reliefs after the company submitted an EIS compliance statement to HMRC instead of the intended SEIS compliance statement. This case was appealed unsuccessfully to the UT see X-Wind Power Limited v HMRC [2017] UKUT 0290
In Christianuyi Limited & Others v HMRC [2016] TC05045 a Managed Service Company (MSC) Provider was found to be ‘involved’ with the taxpayers' personal service companies. This is the first time the MSC rules have been considered by the Courts since their introduction in 2007.