In J Charman v HMRC [2018] TC06899 a taxpayer was found to still be UK resident when he received a founders fee of £1.7m; he had started to cut ties with the UK but not yet made a decisive break.
SME Tax News
The government has launched a consultation on plans to introduce a Stamp Duty Land tax (SDLT) surcharge for non-residents buying residential UK land and property.
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This time, we feature some useful new guides to assist you in planning for the end of the tax year as well as making a review of topical cases.
In Rupert Grint v HMRC [2019] UKUT 0028 the Upper Tribunal (UT) confirmed that Harry Potter star Rupert Grint's accounts did not meet the requirements for a change of accounting date for tax; the accounting period was too long.
In Stephen May v HMRC [2018] TC6928, the First Tier Tribunal (FTT) held that a horizontal silo was plant for capital allowance purposes.
Following recent discussions with the Treasury sub-committee, HMRC have updated their guidance on the settlement terms being offered for disguised remuneration and contractor loan schemes ahead of the loan charge in April 2019.
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The chancellor has announced date of his Spring Statement. This is an not an additional budget (Budget 2019 is scheduled for the Autumn), we might though expect further announcements on key measures such as Making VAT digital and perhaps hear more on certain outstanding consultations, such as employment status.
In Gavin Faulkner v HMRC [2018] TC6500, the First Tier Tribunal (FTT) agreed that the inability of a member of a limited liability partnership to obtain figures for a loss claim can be a reasonable excuse for late filing.
HMRC recently issued a new factsheet about the Disguised Remuneration Loan Charge. Tax barrister Keith Gordon has published a ‘line by line takedown’ of the factsheet. We thought it might be interesting to add a different point of view.
In DAC Beachcroft LLP v HMRC [2018] TC 6704, the first tier tribunal (FTT) found that legal advice privilege (LAP) applied to conveyancing documents sought by HMRC during enquiries.