In John Douglas Wardle v HMRC [2024] TC09213, the First Tier Tribunal (FTT) allowed a claim for Entrepreneurs' Relief (now renamed Business Asset Disposal Relief (BADR)). for the disposal of a Limited Liability Partnership (LLP) interest. Mr Wardle's successful appeal comes after losing two previous appeals on similar grounds for a disposal of an interest in the same partnership.
In Michael Saunders v HMRC [2024] TC09129, the First Tier Tribunal (FTT) found that a Long Term Incentive scheme payment made after an employee had left the UK was taxable because it was general earnings attributable to work done in the UK whilst still resident.
In Philip Cox and Deborah Cox v HMRC [2024] TC09198, the First Tier Tribunal (FTT) found that the taxpayers' incorrect claim for Entrepreneurs’ Relief (now known as Business Asset Disposal Relief) was made carelessly. The taxpayers failed to obtain appropriate professional advice and were liable to penalties of 15% of the Potential Lost Revenue (PLR).
Draft amendments to the Companies Act 2006 will see stringent identity verification procedures introduced for those setting up, running or controlling companies. It aims to stamp out money laundering through fake identities.
There are some curious typos in a HMRC Income from Property information request letter which is combined with an evident misunderstanding of HMRC's powers. Upon closer inspection, it looks suspiciously like the work of ChatGPT, or is it just human error?
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This week we look at the 'tax gap', report on a rare victory for a taxpayer in a Stamp Duty Land Tax (SDLT) appeal, learn a little bit more on the unallowable purpose rule in loan relationships and have news on NICs refunds. All in all another interesting week in tax!
HMRC have published their annual estimates of the 'tax gap'. Ignorance of tax law as in 'failure to take reasonable care' by small businesses is blamed for a large percentage of the tax gap primarily through a lack of Income Tax and Corporation Tax receipts.
In Marie Guerlain-Desai v HMRC [2024] TC9203, a taxpayer successfully persuaded the First Tier Tribunal that a 12-acre woodland behind a dwelling did not form part of its grounds for Stamp Duty Land Tax (SDLT) purposes. As such, the lower non-residential rate applied to the purchase.
With the P11D deadline of 6 July fast approaching, HMRC have issued a reminder for employers needing to declare they have no Class 1A return of National Insurance contributions (NIC) to make.
In Joanne Lunn and Vanilla Monsoon Ltd v HMRC [2024] TC09197, clients of the discredited Christopher Lunn failed to make disclosures when invited by HMRC following the enforcement of a search warrant. It led to HMRC making Discovery Assessments with the addition of tax-geared penalties for failure to take reasonable care.
