The All-Party Parliamentary Loan Charge and Taxpayer Fairness Group (APPG) has launched a call for evidence from advisers with clients affected by the loan charge.
SME Tax News
Following the Bank of England’s recent announcement increasing the base rate, HMRC have announced that their late payment interest rate will also increase by 0.25%, to 3.75%, from 5 July 2022.
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Clearly things are reaching some kind of breaking point at HMRC. It is not every day that four professional bodies write a joint letter to HMRC's Director General of Customer Services to complain about service levels, but they have done just that this week.
Four professional bodies have written to HMRC following record numbers of complaints from their members. It is clear that the joint professional bodies have become totally exasperated with HMRC's poor service levels and an ongoing lack of communication and engagement.
In Idrees Hashmi v Paul Lorimer-Wing and Fore Fitness Investment Holdings Limited [2022] EWHC 191 (Ch) a dispute between a shareholder and company took an unexpected course: the company's articles prevented a sole director from passing decisions. The decision to commence legal action against the dissenting shareholder was thus ultra vires.
HMRC have published their Employer Bulletin for June 2022. We have summarised the key content for you, with links to our detailed guidance on the topics covered.
Further to the responses received as part of its 'OECD Pillar 2: Consultation on implementation' on setting a global minimum tax rate, the Government notes that companies have expressed key concerns centred around early implementation. It indicates that the global minimum tax rate will not be introduced until 31 December 2023.
In Seamus Kavanagh v HMRC [2022] TC08500, the First Tier Tribunal (FTT) found that an individual holding 4.997% of a company was unable to benefit from Entrepreneurs’ Relief on its sale. There was no evidence of other shareholders holding any shares on trust for Mr Kavanagh.
In Elaine Curtis v HMRC [2022] TC 8499, the First Tier Tribunal (FTT) ruled that while a loan received was related to a pension transfer and represented an Unauthorised Member Payment, HMRC had not raised a valid discovery assessment to collect the resulting tax.
In Ignatius Tedesco v HMRC [2022] TC8498, the First Tier Tribunal (FTT) found that the repayment of secured debt was not a deductible expense for Capital Gains Tax (CGT) purposes despite it being a condition of sale.