In HMRC v Jasper Alexander Thirlby Conran & JC Vision Ltd v HMRC [2022] UKUT 166, the Upper Tribunal found that the value of the designer's optical business on incorporation was £1 and not £8m. The difference was taxable as a distribution and not as a capital gain. Intangibles relief claimed by the purchasing company was also reduced to the market value of £1.
SME Tax News
HMRC have published their list of tax avoidance litigation decisions for the 2022-23 year. This identifies the results in litigation decisions where HMRC considered that tax avoidance was involved. The summary indicates increased litigation and a high win rate for HMRC.
HMRC have published a report detailing their current approach to handling Research & Development (R&D) tax relief claims. The number and value of claims are rising and so is the associated non-compliance with it standing at nearly 25% for the SME scheme.
In Sonder Europe Limited v HMRC [2023] TC08853, the First Tier Tribunal (FTT) agreed that the onward supply of rented apartments meant the appellant was a tour operator within the scope of the Tour Operator’s Margin Scheme (TOMS).
The Treasury Committee has launched a new call for evidence ‘Sexism in the City’ looking again at the barriers faced by women in the financial services sector.
Despite an upbeat and confident review of HMRC's annual report and accounts for 2022 to 2023 by its executive, the results of HMRC's annual customer satisfaction survey revealed that taxpayers are still dissatisfied with the HMRC's performance and demand for phone contact with HMRC remains buoyant.
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Is it time to reform the tax rules on employee expenses? There are some very harsh rules that determine whether an employee can obtain tax relief for the costs expended for the purposes of an employment.
HMRC have advised that sole trader and partnership businesses and their agents will soon be able to use an online form to request details of overlap relief available for offset during the transition to the new tax year basis period rules.
In HMRC v Jayanth Kunjur [2023] UKUT 154, the Upper Tribunal (UT) confirmed no tax relief is available for the accommodation expenses paid by a junior doctor. While renting accommodation close to his hospital enabled him to perform some of his duties, the expense was not incurred in the course of the performance of his duties.
As part of a new trial, HMRC has launched a new issue resolution service to process postal correspondence over 12 months old for agents.