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This week, we wonder whether HMRC are sending out too many 'One-to-many' letters, we muse on the fact that it has taken HMRC seven years to issue Simple Assessments and we consider tax on public sector pay. We have more news and case reports too.
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The new Chancellor, Rachel Reeves, will present her first budget in October and this week published details of some of the new government’s tax reforms. We take a closer look at the changes to Furnished Holiday Letting (FHL) and non-domiciled taxation.
The Chancellor, Rachel Reeves, has announced that the first budget of the new parliament will be held on 30 October 2024. We consider the Chancellor's options to repair a £22 billion 'hole' in the public finances. A range of measures that are in line with Labour's manifesto were also announced this week. We take a closer look at what is to come.
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In this week's tax update, we feature HMRC's new Agent Update, consider the Budget Responsibility Bill and have a Court of Appeal decision on Double Tax Relief. There is more from the tribunals on Research & Development relief (R&D).
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The King's Speech did not reveal anything that we did not really know in terms of the new government's policies, and subsequently it published more detail on the first bills that will go before the new parliament. HMRC is really ramping up the stakes now by sending out 'one to many' letters to Persons of Significant Control (PSC) on the Companies House register as well as to deemed contractors under the Construction Industry Scheme (CIS) rules: watch out for these: they constitute a 'nudge' and need to be acted upon. We have several tax cases which are all topical in their own right, covering Research & Development (R&D), carried interests, tax relief on investment management fees and failure to notify.
In Get Onbord Limited (in liquidation) v HMRC [2024] TC09238, the First Tax Tribunal (FTT) considered the meaning of R&D as whether a project heavily reliant on Open Source coding and software to develop a streamlined and AI-automated process for onboarding new clients under the Money Laundering Regulations (MLR) was actually engaged in 'research and development' in terms of the BEIS Guidelines. The FTT also advised future claimants on their approach to case management.
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