In Marcus and Karen Jays v HMRC [2022] TC8639, two shareholders avoided dividend tax discovery assessments when their company declared large final dividends. They were denied an enforceable right to receive payment due to an agreement made with their bank to restrict the size of dividends. HMRC had assessed the amounts voted and not paid.
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In HMRC v Centrica Overseas Holdings Limited [2022] EWCA Civ 1520, the Court of Appeal confirmed that professional fees incurred in the run-up to the disposal of a subsidiary were expenses of management but also agreed with HMRC that they were also capital in nature as so to be disallowed.
In Mrs A v HMRC [2022] TC8640, the First Tier Tribunal (FTT) held that a compensation payment made to an employee who agreed not to pursue her grievances at the Employment Tribunal was fully taxable as a payment for a restrictive undertaking. The £30,000 termination payment exemption did not apply.
HMRC are writing to individuals who have ceased to be Persons with Significant Control (PSC), according to records held by Companies House in the 2021/22 tax year reminding them that disposals can lead to reporting requirements and Capital Gains Tax (CGT) to Pay.
HMRC have issued their Agent Update for November 2022. We have summarised the key content for you with links to our detailed guidance on the topics covered.
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We are a little late off the press today so that we can include a summary of the Chancellor's Autumn Statement 2022. We also have summaries of other tax news and announcements for you.
The Chancellor, Jeremy Hunt has presented his Autumn Statement 2022. This is the UK's third fiscal event this Autumn. The Statement was accompanied by a report by the Office of Budget Responsibilities.
In his Autumn Statement 2022, the Chancellor, Jeremy Hunt announced changes to the Dividend tax allowance, the threshold for the Additional rate of income tax, the Capital Gains Tax annual exempt amount and Inheritance Tax bands and allowances.
Autumn Statement 2022 has been accompanied by a Consultation entitled 'Audio-visual tax reliefs' which seeks views on reforms to simplify and modernise the relief to support growth in the sector.
In the Autumn Statement on 17 November 2022, the Chancellor announced changes to the available R&D Tax Relief rates, in a move aimed at targeting abuse, increasing compliance and rebalancing the relief.