In Syngenta Holdings Limited (SHL) v HMRC [2024] TC0934, the First Tier Tribunal (FTT) ruled that SHL's decision to enter into a loan was driven by the wider group strategy to obtain a tax advantage. The main purpose of securing this tax advantage rendered the loan to have an unallowable purpose.
In Sinter Site Services Ltd v HMRC [2024] TC09343, the First Tier Tribunal (FTT) found that a family company's Coronavirus support claims for its various family members employees were calculated on future unpaid earnings and were excessive.
In Mr and Mrs Murphy v HMRC [2024] TC9324, the FTT calculated that the chargeable consideration created under a failed Stamp Duty Land Tax (SDLT) sub-sale scheme was substantially greater than the chargeable consideration on the actual sales proceeds of the property.
HMRC have published the summary of responses for their 'Consultation on additional tax relief for visual effects costs'. The consultation outlined the scope of visual effects and how the additional tax relief will work.
In Refinitiv Ltd & Ors v HMRC [2024] EWCA Civ 1412, the Court of Appeal (CoA) held that Diverted Profits Tax (DPT) notices were correctly issued and were not inconsistent with an Advance Pricing Agreement (APA), as the five-year term to which the APA applied had expired.
HMRC have published new advisory fuel rates for company car drivers that apply from 1 December 2024.
In light of the substantial increase in the National Living Wage (NLW) and National Minimum Wage (NMW) rates From April 25, it is crucial for employers to understand the implications and risks. Jeni Morris, Head of EY National Minimum Wage Technical Team, explores the key risk areas and identifies who might be most vulnerable.
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The Autumn Budget changes to Capital Taxes herald a 'golden age' for Private Client tax specialists and even led to James Murray MP, Exchequer Secretary to the Treasury, making an appearance on BBC's Newsnight where he clearly recommended that those impacted by the tax changes should consult the services of a tax adviser. Hopefully, we can help out there!
HMRC has launched a new consultation 'The Tax Administration Framework Review: New ways to tackle non-compliance'. This invites views on whether HMRC’s approach to correcting taxpayer inaccuracies in a claim or return could be improved.
In Darren Wragg v HMRC [2024] TC09350, the First Tier Tribunal (FTT) found that a lack of funds owing to the terms of an asset sale agreement did not amount to a reasonable excuse for the late payment of Capital Gains Tax (CGT).
