Conrad Young gave the Chartered Institute of Taxation (CIOT)'s 2024 CTA address last week to a packed audience on The impact of AI on tax. What do tech expert Chartered Tax Advisers (CTAs) think is going to be the impact of AI on tax?

Conrad Young gave the Chartered Institute of Taxation (CIOT)'s 2024 CTA address last week to a packed audience on The impact of AI on tax. What do tech expert Chartered Tax Advisers (CTAs) think is going to be the impact of AI on tax?

In Kaljinder Singh Kalay v HMRC [2024] TC9155 an EIS investor’s attempt to persuade the FTT to allow a late claim for Income Tax relief to effect CGT relief on an £8m disposal failed. The tribunal had no jurisdiction to allow the late claim.
In Elizabeth Rooke v HMRC TC09170 [2024] the FTT had to recalculate CGT on the disposal of a flat, jointly owned by siblings, one of whom did not understand the rules and had acquired her interests at different stages. To cap it all there was Private Residence Relief (PRR).

HMRC have issued the latest round of one-to-many letters, this time focusing on individuals exceeding the lifetime limit for Business Asset Disposal Relief (BADR).
In Digital Buying Partners Limited v HMRC [2024] TC09116, the First Tier Tribunal (FTT) rejected a Coronavirus Job Retention Scheme (CJRS) claim. The employees were deemed ineligible for CJRS payments because they were not included in an RTI submission on or before 19 March 2020.

The Scottish Government has passed the Visitor Levy (Scotland) Bill. This Bill will give councils the power to introduce a local tax on visitors to their area, from 2026.

Missed our SME Tax Web-updates in May? Here is a summary of the month.
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When does a pool car qualify as a pool car? When it meets the relevant qualifying conditions of course! Our tax case this week features an unfortunate situation where an HMRC inspector tried to help an employer set a carpool policy. Unfortunately, the employer misinterpreted the rules, the qualifying conditions for tax-free pooling were not met, and HMRC raised an assessment.

The issuing of Employment-Related Securities Bulletin 55 (May 2024) is a useful reminder that the online filing season has begun for all employment-related securities (ERS) matters.
In MWL International Ltd and Maywal Ltd v HMRC [2024] TC09169 a HMRC inspector agreed a company pool car policy with an employing company, subsequently HMRC changed its view and raised a NICs assessment. On appeal the First Tier Tribunal (FTT) found that HMRC cannot be estopped from enforcing the law. The representation made by the inspector was invalid as the inspector had no legal authority to enter into an agreement relating to the future tax treatment of the cars.
