In JTI Acquisition Company (2011) Limited v HMRC [2024] EWCA Civ 652, the Court of Appeal (CoA) agreed with the Upper Tribunal (UT) and the First Tier Tribunal (FTT) that while the appellant made a commercial acquisition using a group loan, the wider group strategy of securing a tax advantage meant the loan had an unallowable purpose.
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As we roll towards the end of June, don't overlook the next major employer reporting obligations: form P11D (returns of benefits and expenses) and the employer's declaration P11D(b). Employment Related Securities (ERS) returns are due by 6 July.
The HMRC notification deadline for the grant of EMI share options has changed, but some plans still require earlier reporting.
In Kenneth Williams v HMRC [2024] TC09171, the failure of a property developer to notify chargeability to tax and the resultant loss of tax was attributed to his negligent conduct. This meant that HMRC were able to raise assessments into past profits some 15 years after the disposal of the properties.
The ICAEW has asked for more time and comprehensive guidance for businesses to implement an effective UK Carbon Border Adjustment Mechanism (CBAM).
The UK's main professional tax and accountancy bodies have made a joint statement in support of the mandatory registration of tax agents.
In Paul Baxendale-Walker v HMRC [2024] UK154, HMRC found its case struck out by the Upper Tribunal (UT) which decided they had 'no reasonable prospect of success' in imposing £14m of tax-geared penalties for failure to provide information because the conditions for a Paragraph 50 Schedule 36 Information Powers penalty could not be met.
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We have something for everyone this week! We look at remittances, IR35, closing tax enquiries, electronic sales suppression, company size changes affecting over 40,000 companies and HMRC changes impacting response times for VAT. Don't forget to sign up for our live CPD webinars: there are two next week. See more information below.
HMRC has regularly been updating ‘List 3’; its list of approved professional organisations and learned societies. Many new organisations have been added over the last six months.
Over 30 countries have created and implemented so-called 'Fiscal Till Systems' to crack down on tax fraud by Electronic Suppression of Sales (ESS), but the UK shows no sign of following suit. Is the slow-burning rollout of Making Tax Digital into a direct tax to blame?
