SME Tax News

In Bluecrest Capital Management (UK) LLP v HMRC [2022] TC8529, the First Tier Tribunal (FTT) held that the salaried members' rules applied to payments made to members of an LLP as disguised salary. Certain bonus payments escaped the rules as the recipient members had significant influence over the Partnership.

In David Howick v HMRC [2022] TC8531, a director who neglected to ensure that a company paid its PAYE and NICs when he took over as its sole director was found not to have acted as a reasonable and prudent man would in the circumstances. His failure meant that HMRC was able to assess him personally for the company's NICs company's debts.

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Amidst a very exciting day at Westminster, we hope that you have some time for tax! We have a Corporation Tax ‘what’s new’ for 2022 for you this week and news of Making Tax Digital software and requirements.

HMRC's July 2022 consultation, 'The taxation of Decentralised Finance involving the lending and staking of cryptoassets – call for evidence', asks for views on the consistency between the economic and tax treatment of lending and staking transactions and puts forward three different options for tax treatment. 

HM Treasury has published a consultation ‘Sovereign immunity from direct taxation: consultation on policy design’ which outlines the government’s proposal to legislate for, and better target, the UK’s exemption from direct tax for foreign sovereign investors, from April 2024.

In Alan Parry Productions Ltd v HMRC [2022] TC08519, the First Tier Tribunal (FTT) held that the control and mutuality of obligation tests were satisfied. The terms of Mr Parry’s contracts with BSkyB were consistent with him being an employee.

 

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