In HMRC v The Quentin Skinner 2005 Settlements [2021] UKUT 0029, the Upper Tribunal (UT) denied a claim for Entrepreneurs’ Relief on the sale of shares by a trust. The individual must have been a qualifying beneficiary throughout the one-year period when the personal company condition was met.
SME Tax News
HMRC's policy briefing 'Supporting organisations to comply with changes to the Off-Payroll Working rules (IR35)' notes a one-year soft landing on penalties and contains some useful examples to illustrate how it expects to deal with PAYE compliance reviews.
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As you might have seen, HMRC has now published details of Income Tax and NICs rates and allowances for next year. We also have the details for calculating car and van benefits. These are free for all to view in the Tax Data section of our website.
In Simon Padfield, Satnam Bhogal, Allan Dunn & Conor McCloskeyv HMRC [2020] TC07983, the First Tier Tribunal (FTT) held that a tax avoidance scheme involving derivative trading to generate an allowable loss and a tax-free gain in separate transactions had to be viewed as a whole, with the gain cancelling out the loss. This is an extended analysis of the case for subscribers.
HMRC have published their Employer Bulletin for February 2021. We summarise the key content for you, with links to our detailed guidance on the topics covered.
In Simon Padfield, Satnam Bhogal, Allan Dunn & Conor McCloskey v HMRC [2020] TC07983, the First Tier Tribunal (FTT) held that a tax avoidance scheme involving derivative trading to generate an allowable loss and a tax-free gain in separate transactions had to be viewed as a whole, with the gain cancelling out the loss.
In Sharon Clipperton & Steven Lloyd v HMRC [2021] TC07998, the First Tier Tribunal (FTT) found that profit extraction scheme that aimed to trigger the Settlements legislation's revert to settlor rule was really just a distribution to the settlor's shareholders. The 'Ramsay principle' applied.
In Sharon Clipperton & Steven Lloyd v HMRC [2021] TC07998, the First Tier Tribunal (FTT) found that a profit extraction scheme that aimed to trigger the Settlements legislation was really just a distribution to the settlor's shareholders.
Certain contributory benefits can be negatively impacted if payments made under a Time to Pay arrangement with HMRC are not allocated correctly.
In RMF Construction Services Ltd v HMRC [2021] TC07995, the First Tier Tribunal (FTT) allowed the company’s appeal against the withdrawal of Construction Industry Scheme (CIS) gross payment status eight years after associated compliance failures.