In Raymond and Diana Eyre v HMRC [2025] TC09498, the First Tier Tribunal (FTT) found that a couple who purchased, renovated and disposed of a property for £27 million were not doing so in the 'nature of trade'. In addition, they were entitled to claim Private Residence Relief.
Following the Bank of England’s announcement on 8 May 2025 that the base rate would decrease to 4.25%, HMRC's interest rates are also decreasing by 0.25%, to 8.25% for late payment interest and 3.25% for repayment interest, from 28 May 2025.
Hello,
We cover a vast array of topics this week, hopefully meaning there is something for everyone! Between them, our mix of cases explore the gift with reservation rules for Inheritance Tax, the UK tax treatment of distributions by a Jersey company from its share premium and the VAT treatment of providing and fitting telematics devices.
In Alexander Beard v HMRC [2025] EWCA Civ 385, the Court of Appeal (CoA) found that distributions made by a company incorporated in Jersey and debited to its share premium account were subject to UK Income Tax, not Capital Gains Tax.
In Afsha Chugtai v HMRC [2025] TC09495, the First Tier Tribunal (FTT) found that a transfer of value made over seven years before death could not be excluded from the estate for IHT purposes as the donor had reserved benefit in the assets gifted.
Parliament's Public Accounts Committee's (PAC) latest report, 'The cost of the tax system', again criticises HMRC's performance, warning that as tax collection costs rise, HMRC needs to put the customer first and be ready to adopt new technologies, including Artificial Intelligence (AI).
The Government has published a response to its consultation, ‘Modernisation of the Stamp Taxes on Shares Framework’. Draft legislation for a new single tax on securities to replace Stamp Duty and Stamp Duty Reserve Tax (SDRT) will be published in due course. The new single tax and an online portal to handle reporting transactions should be in place by 2027.
HMRC have released the April 2025 edition of the Employment-Related Securities (ERS) Bulletin. It contains some useful information and provides a reminder about this year's filing deadline. Here is our enhanced version.
HMRC have announced a £1 billion tech procurement contract for "a strategic Core SaaS CRM Platform, along with core and additional supplementary products to meet the full range of eCRM capability". The contract comes after continued criticism of HMRC's systems from the Parliamentary Public Accounts Committee.
Missed our SME Tax Updates in April? Here is a summary of the month.