Hello
We have updated several key guides for landlords and property owners this time and there are a couple of Private Residence relief (PRR) cases to report which may be of interest to advisers and potential property buyers.
General election delays loan charge review
The Financial Secretary to the Treasury, Jesse Norman, has written to Sir Amyas Morse asking him to send his report on the loan charge review to the new government after the general election.
PRR date of acquisition is completion, not exchange of contracts
In Desmond Higgins v HMRC [2019] EWCA Civ 1860, the Court of Appeal (CoA) has decided that the date of acquisition of an off-plan property for the purpose of Capital Gains Tax (CGT) Private Residence Relief was the date of completion, and not at exchange of contracts.
Nichola's SME tax W-update 31 October 2019
Hello
This week, a case on trade tariffs; even more crazy than ‘VAT on milk shakes’ it transpires that the final tariff tie-breaker uses a process not unlike 'paper, scissors, stone'.
Trust gets 5 years interest free credit on CGT charges
In Trustees of the Panayi A&M Trusts Nos 1-4 v HMRC [2019] TC7406 the First Tier Tribunal interpreted UK law to conform with EU law and allowed Capital Gains Tax exit charges on the migration of a trust to be paid over a five year period.
BBC presenter loses second IR35 appeal
In Christa Ackroyd Media v HMRC UKUT0326 the Upper Tribunal dismissed a TV presenters appeal against IR35 applying to her personal service company; the BBC did exercise sufficient control over her work for an employment relationship to exist.
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