In HMRC v Timothy Bunting [2025] UKUT 00096, the Upper Tribunal (UT) found that relief for a capital loss on a loan to a sports memorabilia trader was not available as the loan had been satisfied by conversion into shares before the loss relief claim was made.
HMRC have published their Agent Update for March 2025. We have summarised the key content with links to our detailed guidance on the topics covered, including changes to company size thresholds for Off-Payroll Working, reporting payrolled benefits for self-assessment and student loan purposes, and changes to the claims process for Creative Industries Tax Reliefs.
Hello,
With the Chancellor’s Spring Statement just a few days away, there is a little less tax news than normal this week. As a result, we continue to focus on planning around the end of the tax year, and we explore some particularly interesting court and tribunal decisions.
HMRC have released a calculator for those affected by the 2024-25 change in Capital Gains Tax (CGT) rates. Taxpayers using HMRC's online tax return filing service may need to use this tool to calculate a CGT 'adjustment figure', as the tax return calculation will not automatically calculate CGT at the new main rates where they apply.
In PD & MJ Limited v HMRC [2025] UKUT 00094, the Upper Tribunal (UT) found that Sky Sports presenter, Phil Thompson, was an employee for Income Tax and National Insurance purposes.
HMRC are calling for clients of Tax Credits Ltd who made paper form applications for tax assignments from 1 January to 26 October 2022 to contact them. This follows a successful ongoing Account Forfeiture Order on the bank accounts of Tax Credits Ltd and prior to the distribution of its assets to the state.
In Executors for the Estate of the late Gertrud Tanner v HMRC [2025] TC09456, the First Tier Tribunal (FTT) found that a Furnished Holiday Letting business did not qualify for Business Property Relief (BPR). The business was mainly one of holding investments.
In Orsted West of Duddon Sands (UK) Limited & Ors v HMRC [2025] EWCA Civ 279, the Court of Appeal (CoA) applied a wider interpretation to the term ‘on the provision of plant', than previous tribunals. This meant that the cost of preliminary studies relating to offshore wind farms qualified for capital allowances.
Hello,
News this week includes a proposed reporting easement for ‘side-hustlers’ and a new service for tax agents to escalate and resolve self-assessment and PAYE queries with HMRC. We also continue to look forward to the new tax year, with a range of new and updated guides and resources.
In Valesca Valentina Yvette Louwman v HMRC [2025] TC09445, the First Tier Tribunal (FTT) reluctantly ruled that the Transfer of Assets Abroad (ToAA) rules applied to Offshore Income Gains (OIGs) and Accrued Income Profits (AIPs) deemed to arise to a UK deemed domiciled taxpayer from non-resident trusts settled before the taxpayer became UK domiciled. The OIGs and AIPs were chargeable to Income Tax as they arose.
