SME Tax News

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.

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.

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.

It was announced at Autumn Budget 2024 that the question as to whether a double cab pick-up is a car or a van will not be decided purely on the basis of weight. This policy will apply from 6 April 2025. 

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. 

Hello

We are continuing to dissect key announcements from the Autumn Budget 2024 this week and we have created a number of adviser and client briefings which we hope you will find useful.

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.

In Isaac Aboagye Frempong vs HMRC [2024] TC09347, the First Tier Tribunal (FTT) confirmed that an inquiry raised by HMRC to assess undeclared income was valid since the payments received were receipts for payment of services as a tax agent.

The Government is extending 'tax conditionality' to animal welfare, transport and waste sectors in the UK and this will likely roll out to further sectors too. A new consultation was published in Autumn Budget 2024 ‘Tackling the hidden economy: expanding tax conditionality to new sectors’. It considers, amongst other factors, whether HMRC can share data with other regulators.