HMRC have updated their policy paper ‘HMRC issue briefing: settling disguised remuneration scheme use and/or paying the loan charge' making it clear that no further changes will be made to the loan charge.
SME Tax News
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I thought that this week would be quite quiet from an editorial point of view, but far from it. In this time's web-update, our highlights are our latest Company Tax update, news of the Jobs Retention Bonus, a useful VAT decision from the Upper Tribunal for online agencies and an updated guide to the taxation of cryptocurrences and cryptoassets.
In July 2020 the government published a consultation on 'CO2 emission performance standards for new passenger cars and light commercial vehicles'. This relates to the regulation of CO2 emission performance standards for new cars and vans from 1 January 2021 as part of the withdrawal from the EU.
HMRC have stepped up their investigations into the tax affairs of the football industry, tripling investigations of individual professional footballers and more than doubling its tax takings from investigations in 2019/2020.
The government has published a consultation paper, 'Non-Contentious Probate Mandating online professional applications'. It proposes changing the non-contentious probate rules to make it mandatory for professional users, such as solicitors and other probate practitioners, to use the online process.
In Armstrong & Haire Ltd v HMRC [2020] TC7780, the First Tier Tribunal (FTT) refused a Corporation Tax deduction for goodwill amortisation. The pre-incorporation businesses had been carried on before April 2002.
In David Merchant and Sarah Gater v HMRC [2020] TC07783, the First Tier Tribunal (FTT) dismissed the appeal made by the taxpayers. It was found that the closure notice issued by HMRC was valid and that the annexe was not a separate dwelling for Stamp Duty Land Tax (SDLT) Multiple Dwellings Relief (MDR).
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This time we have a capital taxes round-up. We look at the options of those thousands of taxpayers who still have Employee Benefit Trust loans, we review some topical cases and we have new CPD.
In Ian Shiner & David Sheinman v HMRC [2020] TC7779, the First Tier Tribunal (FTT) disallowed interest on loans to members of a trading partnership. The loans were taken by the partners as investors and not the partnership and the interest paid was not wholly and exclusively for the partnership trade.
In BlueCrest Capital Management Cayman Limited (& others) v HMRC [2020] TC 07782, the First Tier Tribunal (FTT) agreed that the sale of occupational income rules could apply to charge Income Tax on partnership capital contributions.