In Sarah Thomas v HMRC [2026] TC09861, the First Tier Tribunal (FTT) found that a debt assignment from a company to a shareholder was taxable as an income distribution to the extent that it exceeded the shareholder's loan account. A lack of documentary evidence for the loan account and an obstructive approach did not help the taxpayer.
In Omar Rafique v HMRC [2026] TC09874, the First Tier Tribunal (FTT) found that an application to reinstate a struck-out VAT appeal should be refused. The appellant had persistently failed to comply with tribunal directions and 'Unless Orders', and had repeatedly submitted AI-generated correspondence containing fabricated case authorities.
In Professional Game Match Officials Limited v HMRC [2026] TC09870, the First Tier Tribunal (FTT) found that referees engaged by the company were not employees. The long-standing case emphasises that a 'multi-factorial' approach is required when determining employment status.
Hello,
Close company directors within Self Assessment have additional reporting obligations in their 2025-26 tax returns. We have expanded our commentary on the new requirements in our 'Self Assessment Return 2025/26: What's new?' guide this week, including how percentage shareholdings should be calculated. Do take a look, as the rules might not be as expected.
In Michael Parker v HMRC [2026] TC09868, the First Tier Tribunal (FTT) found that days spent in the UK by an overseas engineer travelling between Iraq, the UK, and holiday destinations could be excluded under the transit days and exceptional circumstances provisions.
HMRC have updated their Tax Agent Handbook in anticipation of the introduction of Multi-Factor Authentication (MFA) when logging into Agent Accounts.
Some taxpayers may have noticed changes to their digital tax coding notice when they log in to their accounts. HMRC began trialling the changes from mid-March and it will continue into June.
HMRC have released new guidance on what happens if an unregistered or suspended tax adviser interacts with HMRC. Further guidance has also been released on what advisers can do if they disagree with HMRC's decision about their registration.
Hello,
It has been another busy week, with cases and updates spanning VAT, Inheritance Tax (IHT), travel and subsistence expenses, the use of multiple agents by taxpayers and HMRC’s latest Spotlight on property business arrangements involving hybrid partnerships and indemnities.
HMRC have published the research paper, 'Research to understand customers’ views on tax adviser authorisation'. It found that most customers reported using authorised tax advisers for three or more services, highlighting the complexity of the tax system. Surprisingly, only about half of the respondents could list the benefits of using multiple agents, but more could list drawbacks.
