In Frenkel v LA Micro Group (UK) Ltd & ors and LA Micro Group Inc v LA Micro Group (UK) Ltd & ors [2024] UKSC 42, the Supreme Court found that an oral agreement between the legal and beneficial owners of shares was enforceable, and created a constructive trust. This meant that the transfer of beneficial ownership to the legal owners did not need to be in writing.
SME Tax News
In MR Currell Ltd v HMRC [2024] UKUT 00404, the Upper Tribunal (UT) set aside a decision made by the First Tier Tribunal (FTT) due to an error of law. This resulted in the UT concluding that a payment from a company to an employee benefit trust was not earnings.

Tax and accountancy bodies have completed a survey of HMRC’s service levels with some uncomfortable findings: well over a third of calls to HMRC are unproductive. The data harvested sets a new baseline standard for improvement and, future monitoring has now been established.
In Beigebell Limited (No. 2) v HMRC [2024] UKUT 382 (TCC), the Upper Tribunal (UT) found that purchases of memory cards were connected to fraud, which the taxpayer should have known about, causing its claim for input tax to be denied.
Mark Drakeford, Cabinet Secretary for Finance and Welsh Language set out the 2025-26 Welsh Budget on 10 December 2024.

Hello
Scotland has set its budget for 2025-26, we look at the UK's Corporation Tax roadmap and reforms to Carried Interest. We are now in office party season and it's still raining in many places. 'Ho, ho ho: is it beginning to feel a bit like 'Christmas'?
In O’Neill Wetsuits Ltd v HMRC [2024] TC09362, the First Tier Tribunal (FTT) found that wetsuits should be classified as ‘vulcanised rubber’ which has a 4% customs duty rate rather than 'textile' which has a 8% customs duty rate.

HMRC have published an Employer Bulletin for December 2024. We have summarised the key content for you, with links to our detailed guidance on the topics covered.

In Lane v Lane [2024] EWHC 2616 (Ch), the High Court found that a father and son had entered into a binding contract for their respective shareholdings to pass to the survivor on the first of their deaths.

Following the Government's announcement of proposals to reform the tax treatment of carried interest, HMRC have published the summary of responses for their call for evidence on 'The Tax Treatment of Carried Interest' and detail of 'Next steps' which include the publication of a new consultation to consider the qualifying conditions.
