In HMRC v Bluecrest Capital Management (UK) LLP [2025] EWCA Civ 23, the Court of Appeal (CoA) found that the incorrect construction of Condition B was used to determine whether the Salaried Member rules applied. Both the First Tier Tribunal (FTT) and Upper Tribunal (UT) erred in law in accepting the broader interpretation of ‘influence’ set out in HMRC’s guidance.
Exchequer Secretary to the Treasury, James Murray MP, has announced an independent review of the disguised remuneration loan charge to be led by Ray McCann, former President of the Chartered Institute of Taxation (CIOT).
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With the Self Assessment filing deadline just a few days away, this week we feature our top tips for last-minute tax registration and tax returns. We also review HMRC’s new Agent Update, flag a potential tax issue for management buyouts (MBOs) and report on several cases, including the Upper Tribunal’s latest decision on the Tour Operators’ Margin Scheme (TOMS).
HMRC have promised to apply the correct tax codes to pension pot withdrawals from April 2025. The change was announced in its 'Pensions schemes newsletter 166' following criticism of the current system that forces pensioners into reclaiming the tax.
HMRC has recently confirmed that the breadth of the rules that create a tax charge on indirect Loans to Participators in s.459 CTA 2010 is likely to affect a wide range of commercial scenarios including where Management Buyouts (MBOs) are financed by borrowing.
HMRC have published their Agent Update for January 2025. We have summarised the key content with links to our detailed guidance on the topics covered, including the classification of double cab pick-ups, a new R&D disclosure facility and the public service pensions remedy digital service.
In Harbron Recruit Ltd v HMRC [2025] TC09395, the First Tier Tribunal (FTT) found ‘reasonable care’ had been taken by a taxpayer who took professional advice regarding CIS deductions and implementing agency worker rules.
In Sarah Yaxley v HMRC [2025] TC09405, the First Tier Tribunal (FTT) found that a taxpayer could not appeal against HMRC’s calculation of Top Slicing Relief.
In Haron Mayet v HMRC [2025] TC09406, the First Tier Tribunal (FTT) found that a taxpayer had deliberately submitted inaccurate self-assessment returns for 20 years, by not declaring income receipts totalling £1.3 million.
Prepare for your May 2025 ATT/CTA exams. Join us on 19th February 2025 at noon for a free study skills session to help prepare you for the exams.
