In John Tenconi v HMRC [2021] TC08088, the First Tier Tribunal (FTT) found that the transfer of a beneficial interest in guarantee rights was a chargeable disposal subject to Capital Gains Tax (CGT) and the rights could not be considered shares for the purposes of Entrepreneurs’ Relief.
SME Tax News
In James and Barbara Mobey v HMRC [2021] TC08103, the First Tier Tribunal (FTT) denied Stamp Duty Land Tax (SDLT) Multiple Dwellings Relief (MDR) on the purchase of a substantial property with a basement annexe. The annexe did not offer the required facilities to be a dwelling in its own right and compromised the privacy of the main house.
Missed our SME Tax Web-updates in May? Here is a summary of the month.
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Our highlights this week include new proposals for Capital Gains Tax (CGT), a Trusts and Estate update and tooth-aching statistics on snack bars.
HMRC have released statistics showing the number and amount of investments made under the Enterprise Investment Scheme (EIS), Seed Enterprise Investment Scheme (SEIS) and Social Investment Tax Relief (SITR) scheme.
HMRC have published new advisory fuel rates for company car drivers which apply from 1 June 2021. Most rates have increased from the rates applicable for the previous three months.
The European Court of Justice (ECJ) has upheld Amazon's appeal against the European Commission's (EC) ruling that an Amazon royalty pricing arrangement agreed with the Luxembourg tax authorities was overstated. The EC had held that the reduction in profits amounted to receiving the equivalent of €250 million of State Aid.
In John Douglas Wardle v HMRC [2021] TC08105, the First Tier Tribunal (FTT) dismissed an appeal against HMRC closure notices denying Entrepreneurs’ Relief as pre-trading activities were insufficient to render the partnership disposal the disposal of a business.
In Michael and Anthea Mullane v HMRC [2021] TC08100, the First Tier Tribunal (FTT) dismissed an appeal against HMRC closure notices denying Multiple Dwellings Relief (MDR) on the purchase of a property with an annexe. The cooking facilities were of insufficient quality to allow the annexe to be occupied as a separate dwelling.
The Office for Tax Simplification (OTS) has published ‘Simplifying practical, technical and administrative issues’, its second report on Capital Gains Tax (CGT). It recommends extensions to certain reliefs and a new 60-day deadline for paying and reporting CGT on residential property sales.