Subcontractors operating under the Construction Industry Scheme (CIS) will no longer be able to request payment deduction statements from HMRC's CIS helpline. From 1 July 2024, the request must be made by post.
SME Tax News
HMRC have recently released several sets of statistics. We summarise some of the key points relating to non-doms, company cars and employee share schemes.

In Roger William Morgan & Anor v HMRC [2024] TC09221, the First Tier Tribunal (FTT) found that the beneficial ownership of land was transferred to a development company under a constructive trust, a year before legal ownership changed.

Missed our SME Tax Web-updates in June? Here is a summary of the month.
In Mr Taher Suterwalla and Mrs Zahra Suterwalla v HMRC [2024] UT 00188, the Upper Tribunal (UT) upheld the First Tier Tribunal's (FTT's) decision that a paddock was not part of the grounds of a residential property.

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This time we feature some detailed analysis of the potential consequences of an 'upstream' loan in a management buyout. We also note that HMRC has some unusual wording in some tax enquiry letters, there is an update on the new identity verification process that will soon be required by Companies House and another useful selection of cases from the tribunals.

In Patrick Rodney Boden & Anor v HMRC [2024] TC09181, the First Tier Tribunal (FTT) found that a partnership could not use the cash basis to exclude nearly £1m of unpaid sales from tax. HMRC’s discovery assessments were valid.

The Chartered Institute of Taxation (CIOT) has recently highlighted concerns about the application of loan to participator rules and their potential 'unfair' effect on legitimate tax planning, such as where an 'upstream loan' is made to fund a management buyout.
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.
