In the Autumn Budget, the Government announced that a second independent review of the loan charge legislation had been commissioned. We look at the current situation for those who have remaining liabilities. Many MPs and tax professionals raised concerns after it became apparent that the first review had not been carried out independently.
Hello
Now that the 'Self Assessment season' is fully underway, this week we have a broad range of updates, new guides and checklists that will support you. We also continue our review of Budget Announcements and the new Finance Bill has been published.
HMRC have published the outcome of their call for evidence ‘The Tax Administration Framework Review: enquiry and assessment powers, penalties, safeguards’. This explored wide-ranging possibilities for reform, and further consultation will now follow.
HM Treasury has published a response and delivery report following its 2023 consultation 'Help to Save Reform'. Several changes have been announced, including widening the scheme's eligibility criteria, paying bonuses more frequently and changing the bonus calculation method.
In Equity Advisory Ltd & Craig Allan Mellor v HMRC [2024] TC09334, the First Tier Tribunal (FTT) found that 'a capital sum' declared as compensation was a payment of earnings and was not capital after all. It was liable to Income Tax and National Insurance Contributions (NICs).
In Stephen Ray v HMRC [2024] TC09340, the First Tier Tribunal (FTT) found that being party to a judicial review was no excuse for late payment of Accelerated Payment Notices (APN) and penalties by their due date.
In Paul Needham vs HMRC [2024] TC09342, the First Tier Tribunal (FTT) found that failure to receive ‘notice to file’ letters and a prolonged lack of engagement from HMRC, were not reasons to permit a late appeal.
In the Autumn Budget 2024, the Government issued a rather unusual Call for evidence on 'Tackling off-shore anti-avoidance'. The premise sounds simple: to understand the complexities of the Settlements legislation, the Transfer of Assets Abroad legislation and Capital Gains Tax in relation to offshore avoidance.
It was announced at Autumn Budget 2024 that unused pension funds and death benefits will be subject to Inheritance Tax (IHT) from 6 April 2027. A new consultation considers the mechanics of IHT collection and includes several useful examples to illustrate how the new rules will be applied to different types of schemes. Transfers to overseas pensions will also now be in charge. We take a close look.
In Collins Construction Limited (CCL) v HMRC [2024] TC09332, a company's claim for SME R&D tax relief was upheld by the FTT, who found, contrary to HMRC's allegations, that the relevant expenditure was not subsidised and it was not incurred in relation to activities which were contracted out to it either.
