In the case of Peter Marano v HMRC [2024] EWCA Civ 876, the Court of Appeal found the automatic issue of a penalty notice was sufficient to demonstrate its authorisation by HMRC and dismissed the appeal.
SME Tax News
The number of live cases being investigated and reviewed under the Corporate Criminal Offences (CCO) regime for the failure to prevent the facilitation of tax evasion has remained largely stable since HMRC's previous update in January 2024.
HMRC have published draft legislation detailing how the abolition of the Furnished Holiday Letting (FHL) rules in April 2025 will operate. What does this mean?
The Chancellor, Rachel Reeves, has committed to taking action concerning the ‘carried interest’ loophole and has issued a Call for Evidence. In particular, the government is seeking detailed engagement with expert stakeholders.
HMRC have published a policy paper, 'Multinational top-up tax and domestic top-up tax — transitional country by country reporting safe harbour anti-arbitrage rule'. The draft legislation aims to prevent taxpayers from engaging in avoidance arrangements to benefit from the transitional Country-by-Country Reporting (CbCR) safe harbours.
The Chancellor, Rachel Reeves, has announced that the first budget of the new parliament will be held on 30 October 2024. We consider the Chancellor's options to repair a £22 billion 'hole' in the public finances. A range of measures that are in line with Labour's manifesto were also announced this week. We take a closer look at what is to come.
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In this week's tax update, we feature HMRC's new Agent Update, consider the Budget Responsibility Bill and have a Court of Appeal decision on Double Tax Relief. There is more from the tribunals on Research & Development relief (R&D).
HMRC have published Agent Update 121 for July 2024. Here is our summary of the highlights in direct and indirect tax announcements affecting SME owners and advisers.
In GE Financial Investments Limited v HMRC [2024] EWCA Civ 797, the Court of Appeal (CoA) overturned the Upper Tribunal’s (UT’s) decision that the UK-incorporated company was also US resident under the UK/US Double Tax Agreement (DTA). The claim for Double Tax Relief (DTR) in the UK was denied.
