SME Tax News

Thinking of starting a new accountancy practice? Thinking of restructuring your existing business? What would you do if you could start afresh?

In HMRC v Sukhdev Mattu [2021] UKUT 0245, the Upper Tribunal approved penalties for non-compliance with a Schedule 36 information notice. The tax at stake was high and the taxpayer had failed to cooperate with HMRC.

In Peter Wilson v HMRC [2021] UT 0239, an accountancy Limited Liability Partnership ( LLP) member lost an argument that he was a he was an employee and not a partner for National Insurance Contributions (NICs). Changes to the LLP agreement had hollowed out many of his original membership rights but he still retained enough voting rights and a profit share to be treated as a partner.

In Vitol Aviation UK Limited & Ors v HMRC [2021] TC08287, the First Tier Tribunal (FTT) found that HMRC had sufficient information on the applicants' transfer pricing model to issue closure notices and that an ongoing enquiry into Diverted Profits Tax (DPT) was not reasonable grounds for refusing to do so.

Accountants don’t take time enough for themselves for Inheritance Tax planning, especially when they’re younger. That’s one of the points our tax consultants Rachel Davies and Andrew Symons intend to hammer home in their conference presentation on IHT for accountants at next week's Virtual Tax Partner Practical tax conference.

In Sheiling Properties Ltd v HMRC [2021] EWCA Civ 1425, the Court of Appeal agreed that an Accelerated Payment Notice (APN) could be issued to an employing company for PAYE liabilities determined under Regulation 80. The amounts determined were ‘disputed tax’ under the APN rules.

 

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