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SME Tax News
Hello
We are publishing early this week. There are some rather interesting developments from the courts, we have our latest Land and Property update, more 'CPD for lunch' and more Spotlights from HMRC.
In Anthony and Tracy Lee Hancock v HMRC [2019] UKSC 24 the Supreme Court held that that the conversion of QCBs and non-QCBs into a single new QCB were two separate conversions: tax was due on redemption.
HMRC have released two more opinions in their favour from the GAAR advisory panel (GAP) in quick succession; about disguised remuneration, loans to participators, and employee rewards using second hand bonds and gilt options.
HM Treasury have opened a new call for evidence on Social Investment Tax Relief as take up has been poor and the the relief is currently due to end in 2021.
In Hopscotch Limited v HMRC [2019] TC07127 the FTT found that the redevelopment of a single house in order to sell it was not a property development trade; no ATED relief was due.
In Raymond Tooth v HMRC [2019] EWCA 826 the Court of Appeal confirmed that HMRC's delay in raising a discovery assessment had rendered it invalid. The decision was subsequently appealed by HMRC. The Supreme Court under different reasoning ruled that there was no discovery.
In Mr Douglas Shanks v HMRC [2019] TC07118 the FTT cancelled penalties for inaccuracies but disallowed partnership losses; they were not substantiated and from a different trade to the profits against which they were being offset.
Hello
We are taking a break from reporting cases this week, as we have picked out quite a diverse range of news items and we also have a bumper capital taxes update.
The government has opened a consultation on the UK's approach to carbon pricing after Brexit, to consider various options to enable the UK continue to meet its carbon reduction targets after we leave the EU.