In Conegate Limited v HMRC [2018] TC06340 the FTT denied a claim for capital loss relief: market value should have been applied to the disposal and one of the main purposes for entering into the transaction was to secure a tax advantage.
SME Tax News
Following the introduction of tax-free childcare for all from February 2018 the childcare voucher scheme was due to close to new entrants in April 2018; this has now been extended by six months.
HMRC have issued the Agent Update for February/March 2018. We have summarised the key content for you with links to our detailed guidance on the topics covered.
In City Shoes Wholesale Ltd & Ors v HMRC [2018] EWCA Civ 315 the Court of Appeal agreed there was no conspicuous unfairness leading to an abuse of power by HMRC in denying the Liechtenstein Disclosure Facility (LDF) to users of EBT schemes.
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In this web-update we look at HMRC's powers when it comes to issuing third party information notices to accountants, we feature our all new toolkits for non-residents with offshore property, non-UK domiciled taxpayers and much, much more.
Ex parte A Taxpayer v HMRC [2018] TC6330 considered HMRC's options in serving a third party information notice in respect of a PAYE/NIC enquiry on the accountant of a company that had gone into liquidation. The answer was to treat the company director as the taxpayer.
HMRC have confirmed that the current Annual Tax on Enveloped Dwellings (ATED) Relief Declaration Return (RDR) forms will be withdrawn on 31 March 2018.
In Roy Stanley v HMRC [2018] TC6199, a taxpayer was regarded as careless after supplying delayed and incomplete information to his agent. His agent also made share loss and negligible value claims out of time, despite being told that they were out of time by HMRC. The taxpayer was not penalised for his agent's actions.
HMRC have now issued details of late filing penalties in respect of the new online trust registration service.
In Trent Personnel Ltd v HMRC [2018] TC06319 FTT overturned penalties charged for a late form P11D(b) return. The judge deduced that penalties were appealable and made via a s100 TMA determination. HMRC failed to provide any evidence that the penalty was made by a human.