HMRC has recently confirmed that the breadth of the rules that create a tax charge on indirect Loans to Participators in s.459 CTA 2010 is likely to affect a wide range of commercial scenarios including where Management Buyouts (MBOs) are financed by borrowing.
HMRC have published their Agent Update for January 2025. We have summarised the key content with links to our detailed guidance on the topics covered, including the classification of double cab pick-ups, a new R&D disclosure facility and the public service pensions remedy digital service.
In Harbron Recruit Ltd v HMRC [2025] TC09395, the First Tier Tribunal (FTT) found ‘reasonable care’ had been taken by a taxpayer who took professional advice regarding CIS deductions and implementing agency worker rules.
In Sarah Yaxley v HMRC [2025] TC09405, the First Tier Tribunal (FTT) found that a taxpayer could not appeal against HMRC’s calculation of Top Slicing Relief.
In Haron Mayet v HMRC [2025] TC09406, the First Tier Tribunal (FTT) found that a taxpayer had deliberately submitted inaccurate self-assessment returns for 20 years, by not declaring income receipts totalling £1.3 million.
Prepare for your May 2025 ATT/CTA exams. Join us on 19th February 2025 at noon for a free study skills session to help prepare you for the exams.
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This week we note changes to Welsh Land Transaction Tax (LTT), a variety of HMRC ‘nudge’ letters, and some of the latest decisions from the tax tribunals, including the VAT status of fundraising activities by charities, a non-resident's appeal against Self Assessment late filing penalties and Capital Allowances at ports.
In The Mersey Docks and Harbour Company Limited v HMRC [2024] TC09391, the First Tier Tribunal (FTT) allowed a claim for Plant and Machinery Allowances (PMAs) for expenditure incurred on the construction of a quay wall. The quay wall was a distinct asset that functioned as 'plant' and was not part of the premises in which the business is carried on.
In SWG Polymer Services Ltd v HMRC [2025] TC09398, the First Tier Tribunal (FTT) found that Coronavirus Job Retention Scheme (CJRS) payments made whilst an employee was still working were invalid and should have been repaid to HMRC.
The Welsh Government has laid draft regulations to amend the Land Transaction Tax (LTT) rules surrounding the combined use of Multiple Dwellings Relief (MDR) and the Subsidiary Dwelling Exception (SDE).
