In Get Onbord Limited (in liquidation) v HMRC [2024] TC09238, the First Tax Tribunal (FTT) considered the meaning of R&D as whether a project heavily reliant on Open Source coding and software to develop a streamlined and AI-automated process for onboarding new clients under the Money Laundering Regulations (MLR) was actually engaged in 'research and development' in terms of the BEIS Guidelines. The FTT also advised future claimants on their approach to case management.
King Charles III made his speech on the State Opening of Parliament today. He confirmed the 'big ticket measures' that the new government will privatise the railways and introduce a new Great British Energy company. In terms of business and tax it will ensure that every decision is consistent with set fiscal rules and scrutinised by the Office of Budget Responsibility, there will be reforms of audit and corporate governance and new measures on pensions and investment. VAT will be charged on private school fees.
HMRC has made Form P1000 available on gov.uk. Agents should use Form P1000 when requesting authority to act as personal representatives of an estate.
In Nicholas Millican v HMRC [2024] TC09239, the First Tier Tribunal (FTT) found that the post-July 2015 carried interest rules did not apply for Capital Gains Tax (CGT) purposes. Although the individual supplied investment management services, they were not supplied to an investment scheme.
In its latest one-to-many campaign, HMRC is writing to Persons with Significant Control (PSC) who have not filed a tax return or may not have declared all their income, according to the Institute of Chartered Accountants in England and Wales (ICAEW). We note that HMRC's letter will count as a 'prompt' if any income or gains have not been reported under Self Assessment.
In Roy Bevan v HMRC [2024] TC09225, a landlord was unsuccessful in his appeal against tax penalties assessed for his failure to declare small amounts of rental income over 15 years. The tribunal decided that "it was not objectively reasonable" for the Appellant to have failed to consider the ramifications of renting out a property.
In Centrica Overseas Holdings Limited v HMRC [2024] UKSC 25, the Supreme Court (SC) confirmed that professional fees incurred in relation to the disposal of a subsidiary were management expenses. However, the SC agreed with the Court of Appeal (CoA) that these expenses were capital in nature and should therefore be disallowed.
HMRC have issued the latest round of one-to-many letters, focusing on Construction Industry Scheme Insurance Sector Registrations.
Hello,
Now that the election period has concluded, we wait to see what changes in the tax world will be announced.
HMRC have published their Employer Bulletin for July 2024. We have summarised the key content for you, with links to our detailed guidance on the topics covered.
