Tax Take
Tax Bites – June 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTribunal dismisses HMRC's appeal and confirms transactions did not give rise to a taxable remittance
In dismissing HMRC's appeal, the Upper Tribunal confirmed that transactions entered into by the taxpayers for the sale of shares did not amount to a taxable remittance under section 809L of the Income Tax Act 2007 because no service was provided in the UK.
Read moreKey features of the new non-UK domicile regime
The UK government's unexpected announcement in Spring Budget in March on the taxation of non-domicile individuals has sparked concerns and much comment. It represents a major change to the current system of taxation, which is more than 200 years old.
Read moreV@ update – May 2024
Welcome to the May 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world.
Read moreCustoms and excise quarterly update - May 2024
Welcome to the May 2024 edition of RPC's Customs and Excise Quarterly Update.
Read moreThe latest on the loan charge scandal with Matt Hall from Armadillo
In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Chartered Tax Adviser, Matt Hall from Armadillo to discuss the latest on what is often referred to as the "loan charge scandal".
Read moreTaxpayers' application for protective costs order against HMRC refused
UT dismisses taxpayer's application for a protective costs order against HMRC.
Read moreContentious Tax Update
Harry Smith and Adam Craggs examine developments in relation to DOTAS, R&D enquiries, and the Economic Crime and Transparency Act.
Read moreTribunal allows taxpayer's appeal in R&D case against penalty assessment for careless inaccuracy
In H & H Contract Scaffolding Ltd v HMRC [2024] UKFTT 00151 (TC), the First-tier Tribunal (FTT) allowed the taxpayer's appeal against a penalty assessment as the inaccuracy in the tax return was not careless.
Read moreTax Bites – May 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreContentious tax quarterly: Spring review
The last few months have seen a flurry of activity in relation to the DOTAS regime, with HMRC seeking to register arrangements retrospectively and apply substantial penalties for failure to register. Woes continue for those unfortunate enough to have R&D claims under enquiry, and the Economic Crime and Corporate Transparency Act 2023 gives HMRC a significant new tool in relation to suspected criminal activity by bodies corporate and partnerships.
Read moreChanges to non-domiciliary rules with Philip Simpson KC and Ben Symons
In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team is joined by Philip Simpson KC and Ben Symons from Old Square Tax Chambers, to discuss the Government's Spring Budget and, in particular, the proposed changes that will affect non-UK domiciled individuals.
Read moreTaxpayer's appeal against penalties under the Follower Notice regime allowed
In Baker v HMRC [2024] UKFTT 126 (TC), the First-tier Tribunal allowed the taxpayer's appeal and cancelled follower notice penalties that were issued as a result of the taxpayer's alleged failure to take 'corrective action'.
Read moreV@ update – April 2024
Welcome to the April 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.
Read moreTax Tribunal upholds taxpayer's appeal in respect of remote gaming duty
In allowing the taxpayer's appeal, the First-tier Tribunal determined that cashback payments constituted prizes won for the purposes of section 157 of the Finance Act 2014 and Remote Gaming Duty.
Read moreCostly objection by HMRC
FTT allows costs application where HMRC acted unreasonably in opposing specific disclosure application.
Read moreUpper Tribunal upholds penalty imposed for failing to take 'corrective action' in response to a follower notice
Upper Tribunal dismisses taxpayer’s appeal against a penalty issued under the follower notice regime for failing to take corrective action, as the final judicial ruling specified in the follower notice was relevant to the arrangements the taxpayer had implemented.
Read moreTax Bites – April 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTribunal allows appeals against discovery assessments
In Charles Collier and CB Collier Partnership v HMRC [2023] UKFTT 00993 (TC), the First-tier Tax Tribunal (FTT) found that the assessed loss of tax was not brought about deliberately by the taxpayers and had occurred due to carelessness. The 6-year time limit therefore applied to HMRC making assessments and amendments and, under that time limit, HMRC were out of time. The taxpayers' appeals were allowed.
Read moreV@ update - March 2024
Welcome to the March 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.
Read moreTaxpayer's appeal succeeds as HMRC failed to open enquiry in time
In Monks v HMRC [2023] UKFTT 853 (TC) the First-tier Tribunal concluded that HMRC had not opened a valid enquiry because the taxpayer didn't receive HMRC's letter until after the relevant time limit had expired.
Read moreSupreme Court provides clarity on Transfer of Assets Abroad legislation
In allowing the taxpayers' appeal, the Supreme Court determined that shareholders were not "transferors" for the purposes of the Transfer of Assets Abroad regime in the Income and Corporation Taxes Act 1988.
Read moreHome run! - Tribunal finds that taxpayer who bought and sold three properties in quick succession was not trading
Taxpayer purchasing, renovating and selling properties allowed private residence relief on capital gain and held not to be trading as property developer for tax purposes.
Read moreInternational Women's Day special – Inspiring inclusion with Tax Titan Trio
To celebrate International Women's Day 2024, we have produced a special episode of RPC's Taxing Matters podcast in which we discuss this year's campaign theme #InspireInclusion and what it means to each of our guest speakers.
Read moreTax Bites - February 2024
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreA look into HMRC's toolbox during a criminal investigation
HMRC has far-reaching powers it can deploy during a criminal investigation into suspected tax fraud, which include applying for and executing search warrants (colloquially referred to as a "dawn raid"), making arrests and the compulsorily obtaining information and documentation through production orders and disclosure notices/orders. A criminal investigation conducted by HMRC is one of the most stressful events a business can experience and failing to properly respond can have serious repercussions, including significant financial and reputational damage or even prison time for individuals.
Read moreV@ update - February 2024
Welcome to the February 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.
Read moreCustoms and excise quarterly update - February 2024
Welcome to the February 2024 edition of RPC's Customs and Excise Quarterly Update.
Read moreTribunal allows taxpayers' appeals against discovery assessments as company could not distribute goodwill it did not own
Tribunal allows taxpayers' appeals against HMRC discovery assessments as company could not distribute goodwill it did not own.
Read moreA whistlestop tour of the taxation of international sports and rock stars with Patrick Way KC
In this episode, RPC's Taxing Matters Host and Senior Associate in RPC's Tax Disputes team, Alexis Armitage, will be discussing the taxation of international sports and rock stars with leading silk, Patrick Way KC.
Read moreTribunal varies Schedule 36 information notice as it sought material not reasonably required by HMRC
In Parker Hannifin (GB) Ltd v HMRC [2023] UKFTT 00971 (TC), the First-tier Tribunal found that an information notice issued by HMRC, under Schedule 36, Finance Act 2008, was not invalid because it required electronic searches using a list of specified search terms but it did seek information that was legally privileged or not "reasonably required" and the notice was varied accordingly.
Read moreUpper Tribunal remits CGT appeal back to Tribunal for rehearing
In M Campbell v HMRC [2023] UKUT 265 (TCC) the Upper Tribunal (Tax chamber) remitted the taxpayers' appeals back to the First-tier Tribunal to consider the liability to capital gains tax, after the taxpayer flipped four residential properties.
Read moreTribunal allows taxpayers' appeals against discovery assessments
In Smith v HMRC [2023] UKFTT 00912 (TC), the First-tier Tribunal (FTT) allowed the taxpayers' appeals against discovery assessments, finding that a transfer of goodwill did not amount to a distribution under section 1000, Corporation Tax Act 2010 (CTA), because the goodwill was owned personally by the taxpayers.
Read moreTax Bites - January 2024
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreAIM higher!
In Graham Chisnall and Others v HMRC [2023] UKFTT 857 (TC), the First-tier Tribunal (FTT) held, in allowing the taxpayers' appeals, that evidence derived from the sale price of shares on the Alternative Investment Market (AIM) was more reliable than evidence provided by a valuer employed by HMRC.
Read moreExploring the World of AI with Olivia Dhein
In this episode we discuss the hot topic of artificial intelligence. We will consider what is AI, what is a large language model and how does it work, what can AI do and not do at the moment as well as some of the potential effects AI might have in the tax world. We also take a look at the recent Tax Tribunal decision in Harber v HMRC [2023] UKFTT 1007 (TC), in which false case law was generated by AI and innocently relied upon by the taxpayer and how the Tribunal dealt with this.
Read moreV@ update - January 2024
Welcome to the January 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.
Read moreTax Tribunal allows taxpayer's appeal against discovery assessment
FTT allows taxpayer's appeal against HMRC discovery assessment seeking to charge CGT on the disposal of a property between separating spouses.
Read moreCourt of Appeal considers 'main purpose' test and finds in favour of taxpayer
Read more
Directors not liable under PLNs as HMRC failed to establish deliberate conduct by company
In Sharon Suttle and another v HMRC [2023] UKFTT 873 (TC), the Tax Tribunal allowed the taxpayers' appeals against Personal Liability Notices (PLNs) on the basis that the company did not make a deliberate inaccuracy in its returns.
Read moreTackling "Tax avoidance" this Christmas season with Sam Brodsky
As the cost of living crisis bites more than ever this year, in this special Christmas episode of RPC's Taxing Matters, we bring you some Christmas cheer by way of a light-hearted discussion of some of the potential ways you may be able to reduce your tax bill. In addition, we'll also have a quick look at Santa's tax position in the run up to Christmas and whether he might be guilty of tax avoidance … or even tax evasion!
Read moreCourt of Appeal upholds tribunal decision on the taxation of limited partnership transactions
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Tax Bites - December 2023
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreUT dismisses HMRC's appeal and upholds decision in relation to private residence relief
Read more
V@ update - November 2023
Welcome to the November 2023 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.
Read moreCustoms and excise quarterly update - November 2023
Welcome to the November 2023 edition of RPC's Customs and Excise Quarterly Update.
Read moreA day in the life of a tax adviser with Jeremy Johnson
In this episode of Taxing Matters, we are joined by Jeremy Johnson, managing director of inTAX Limited.
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