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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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Now that the election period has concluded, we wait to see what changes in the tax world will be announced.

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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.

There are some curious typos in a HMRC Income from Property information request letter which is combined with an evident misunderstanding of HMRC's powers. Upon closer inspection, it looks suspiciously like the work of ChatGPT, or is it just human error?