Tax Take

Perspective - Blog

Penalties for non-payment of APN can be avoided where it is reasonable to consider an APN unlawful

20 December 2017

In Chapman v HMRC, the First-tier Tribunal (FTT) has confirmed that a reasonable belief that an accelerated payment notice (APN) is unlawful can constitute a reasonable excuse for non-payment.

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Spurs 2 : 0 HMRC – payment on early termination of fixed term contract not taxable as earnings

Published on 20 December 2017. By Michelle Sloane, Partner

In Tottenham Hotspur Ltd v HMRC [2017] UKUT 453 (TCC), the Upper Tribunal (UT) has confirmed the decision of the First-tier Tribunal that payments made by an employer in respect of two football players on early termination of their fixed term contracts were not earnings. They were termination payments and, therefore, were outside the scope of national insurance contributions (NICs).

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United Biscuits: High Court rejects claims for refunds of overpaid VAT

18 December 2017

In United Biscuits (Pension Trustees) Ltd and another v HMRC [2017] EWHC 2895 (Ch), the High Court held that pension fund management services by non-insurers are standard rated and dismissed the claimant's claim to recover VAT on investment management services for pensions.

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Barclays Wealth Trustees - normal meaning to apply to 'settlement' for IHT purposes

Published on 11 December 2017.

In Barclays Wealth Trustees (Jersey) Ltd and Michael Dreelan v HMRC [2017] EWCA Civ 1512, the Court of Appeal has confirmed that inheritance tax will not apply in circumstances where a transfer between excluded property settlements takes place after a settlor becomes domiciled in the UK.

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Tax update December 2017

06 December 2017

In this month’s update we report on HMRC’s increased activity in respect of the so-called Panama Papers; HMRC’s new guidance in relation to “enablers” of defeated tax avoidance schemes; new settlement terms concerning disguised remuneration; and HMRC’s updated Litigation and Settlement Strategy

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Jiminez: High Court quashes information notices issued to non-UK resident taxpayer

Published on 05 December 2017. By Adam Craggs, Partner

In Jimenez v (1) HMRC & (2) The First Tier Tax Tribunal [2017] EWHC 2585 (Admin), the High Court has quashed an information notice given by HMRC to a non-UK resident taxpayer.

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VAT update November 2017

29 November 2017

In this month’s update we report on the Office of Tax Simplification’s first report on VAT, the draft regulations concerning the fulfilment house due diligence scheme, and HMRC’s revised guidance on input tax deduction for funded occupational pension schemes.

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Bekoe: Tribunal cancels discovery assessments and penalties issued to taxpayer

27 November 2017

In Edwin Bekoe v HMRC [2017] UKFTT 772, the First-tier Tribunal (FTT) has held that the taxpayer was not liable to assessments and penalties where he had demonstrated that deposits paid into his brother's bank account were loans and not undeclared taxable trading income and HMRC's reliance on the "assumption of continuity" principle had been misplaced.

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Customs and excise quarterly update, November 2017

21 November 2017

In this update we report on the Government’s White Paper setting out its approach to the UK’s future customs, VAT and excise regimes; the Trade Bill 2017-2019; and the implementation of the Fulfillment House Due Diligence Scheme.

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Benham – Upper Tribunal dismisses HMRC's appeal regarding the correct treatment of a purported amendment of a return relating to a failed rollover claim

Published on 20 November 2017. By Alexis Armitage, Senior Associate

In Benham (Specialist Cars) Limited v HMRC [2017] UKFT 389 (TCC), the Upper Tribunal (UT) dismissed HMRC's appeal upholding the decision of the First-tier Tribunal (FTT) that section 153A(4), Taxation of Chargeable Gains Act 1992 (TCGA), does not provide a freestanding right for HMRC to make or amend an assessment in order to bring a rolled-over gain back into charge following the lapse of a declaration of intention to claim roll-over relief made under section 153A(1), TCGA.

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Wealth and trusts quarterly digest November 2017

17 November 2017

Welcome to our latest Wealth and trusts digest. Our quarterly digest provides up to date commentary and analysis on key sector developments. It is written by members of our wealth and trusts team to assist you and your clients in responding to market trends and legal developments. We would welcome the opportunity to discuss any issues you may have and always welcome feedback on the content of our publications.

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The Barty Party – HMRC's information notice was invalid

09 November 2017

In The Barty Party Company Limited v HMRC [2017] UKFTT 697, the First-tier Tribunal (FTT) allowed the taxpayer's appeal against an information notice which HMRC had issued pursuant to Schedule 36, Finance Act 2008, on the basis that the information notice was invalid.

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NCL Investments - Tribunal allows deductions against trading profits in EBT case

Published on 06 November 2017. By Michelle Sloane, Partner

In NCL Investments Limited and another v HMRC [2017] UKFTT 495, the First-tier Tribunal (FTT) held that accounting debits relating to the grant of share options to employees were a deductible expense for corporation tax purposes.

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Tax update, November 2017

02 November 2017

In this month’s update we report on HMRC’s revised guidance relating to venture capital schemes, the coming into force of section 166, Finance Act 2016 (offences relating to offshore income) and HMRC’s new guidance on self-reporting for failure to prevent the facilitation of tax avoidance.

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Corporate tax update, third quarter 2017

27 October 2017

Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s Tax Team and published quarterly.

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VAT update, October 2017

26 October 2017

In this month’s update we report on the processing of personal data to combat tax fraud, the new proposals for taxing intra-EU supplies and the change in VAT treatment of pension fund management services supplied by regulated insurers.

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SUSSEX CARS - Tribunal orders HMRC to pay taxpayer's costs of appeal

18 October 2017

In Sussex Cars Association v HMRC [2017] UKFTT 0691 (TC), the First-tier Tribunal (FTT) has exercised its discretion, under Rule 10(1)(b) of the Tribunal Rules, to make an order for costs against HMRC on the basis that it had "acted unreasonably in bringing, defending or conducting the proceedings".

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McGreevy – Tribunal describes HMRC's argument as "clap trap" in late filing case

Published on 17 October 2017.

In R McGreevy v HMRC [2017] UKFTT 0690 (TC), the First-tier Tribunal (FTT) allowed a non-resident taxpayer's appeal against a penalty for the late filing of her non-resident CGT (NRCGT) return on the basis that she had a reasonable excuse.

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Gill - Tribunal rejects HMRC's interim applications 

Published on 16 October 2017. By Alexis Armitage, Senior Associate

In Gill v HMRC [2017] UKFTT 0597 (TC), the First-tier Tribunal (FTT) dismissed three interim applications made by HMRC for (1) permission to adduce expert evidence; (2) a direction excluding a large amount of documentation adduced by the taxpayer; and (3) a direction that the taxpayer disclose data in an alternative format to that provided by the taxpayer.

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Chadwick – Discovery assessment on wrong person cannot be remedied by section 114 TMA

06 October 2017

In Chadwick (as trustee in bankruptcy of Mrs Gloria Oduneye-Braniffe) v The National Crime Agency [2017] UKFTT 656 (TC), the First-tier Tribunal (FTT) has held than an assessment issued to a trustee in bankruptcy was a gross error that could not be cured by section 114 of the Taxes Management Act 1970 (TMA).

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Tax update, October 2017

04 October 2017

In this update we report on HMRC’s recently published guidance concerning the new offences of failing to prevent the facilitation of tax evasion; HMRC’s new powers to refuse to register or de-register master trust pension schemes; and new guidance on investors’ relief in the CGT context.

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Bailey: Quality trumps quantity as Tribunal grants taxpayer principle private residence relief

27 September 2017

In Stephen Bailey v HMRC [2017] UKFTT 658 (TC), the First-tier Tribunal (FTT) granted the taxpayer principle private residence relief, under section 222, Taxation of Chargeable Gains Act 1992 (TCGA), despite having only occupied the property in question for two periods of less than six months.

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VAT update September 2017

27 September 2017

In this month’s update we report on the Commission’s evaluation of invoicing rules; revisions to VAT notice 700/50, concerning default surcharge; and details of the consultation on the Making Tax Digital reforms.

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Gekko – HMRC's unreasonable conduct leads to costs award against it

19 September 2017

In Gekko & Company Ltd [2017] UKFTT 586 (TC), the First-tier Tribunal (FTT), in allowing an appeal against assessments to VAT and penalties, awarded the taxpayer its costs as HMRC's conduct had been unreasonable.

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Thathiah: HMRC unsuccessful in first senior accounting officer penalty appeal

Published on 13 September 2017. By Michelle Sloane, Partner

In Kreeson Thathiah v HMRC [2017] UKFTT 0601 (TC), the First-tier Tribunal (FTT) allowed an appeal against penalties which had been assessed on the finance director of a group of companies under the Senior Accounting Officer (SAO) regime, contained in Schedule 46, Finance Act 2009 (FA 2009), as HMRC had failed to establish that he had breached his duty as a SAO.

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Settlement considerations following the Rangers decision

08 September 2017

Following the Supreme Court’s recent judgment in the Rangers case, many employers who had established employee benefit trusts (EBTs) are facing enforcement notices in respect of income tax and National Insurance contributions.

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Perspective - Blog

Hickey Plant Hire - Taxpayer successfully challenges HMRC's narrow reading of penalty rules

Published on 07 September 2017.

In M J Hickey Plant Hire and Contracts Ltd v HMRC [2017] UKUT 308 (TCC), the Upper Tribunal (UT) allowed the taxpayer's appeal and in a carefully considered judgment sets out the correct approach to the penalty rules applicable to 'normal' and 'delayed tax' cases, contained in Schedule 24, Finance Act 2007 (FA 2007).

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Tax update, September 2017

07 September 2017

In this month’s update we report on HMRC’s new guidance on asset-based penalties for offshore inaccuracies; the GAAR Advisory Panel’s first published opinion on tax planning involving gold bullion and Spotlight 39 on measures designed to avoid the 2019 EBT loan charge.

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Corporate tax update, second quarter 2017

05 September 2017

Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s tax team and published quarterly.

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Vigne - HMRC lose business property relief case

Published on 04 September 2017. By Alexis Armitage, Senior Associate

In The Estate of Maureen W Vigne (deceased) v HMRC [2017] UKFTT 632 (TC), the First-tier Tribunal (FTT) has determined that the estate of the late Maureen Vigne was entitled to business property relief (BPR), as provided for in section 105, Inheritance Tax Act 1984 (IHTA).

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VAT update August 2017

Published on 30 August 2017. By Adam Craggs, Partner

In this month’s update we report on updated guidance from HMRC on distance selling, the EU (Withdrawal Bill) and the revised place of supply rules for B2C telecommunications.

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BPP – Tribunal correct to strike out HMRC's case for failure to comply with Rules and Directions

23 August 2017

In BPP Holdings Ltd v HMRC [2017] UKSC 55, the Supreme Court has confirmed that the First-tier Tribunal (FTT) was justified in directing that HMRC be barred from taking further part in the proceedings for failure to adhere to the Tribunal’s Rules and Directions.

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Customs and excise quarterly update, August 2017

Published on 22 August 2017. By Adam Craggs, Partner

In this update we report on the implementation of the Fulfillment House Due Diligence Scheme, the National Audit Office's report on the new Customs Declaration Service and the future excise duty rate changes to cooking wine and other cooking alcohol.

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Perspective - Publication

Wealth and trusts quarterly digest, August 2017

15 August 2017

Our quarterly digest provides up to date commentary and analysis on key sector developments.

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Perspective - Blog

Eastern Power – Tribunal orders HMRC to close its enquiries despite outstanding information notices

Published on 10 August 2017. By Adam Craggs, Partner

In Eastern Power Networks Plc and others v HMRC [2017] UKFTT 494 (TC), the First-tier Tribunal (FTT) ordered HMRC to issue closure notices even though there were a number of outstanding information notices.

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Gray – FTT allows appeal against discovery assessment as ITV correctly accounted for PAYE

Published on 03 August 2017. By Michelle Sloane, Partner

In Gray v HMRC [2017] UKFTT 0275, the First-tier Tribunal (FTT) allowed the taxpayer's appeal against a discovery assessment in relation to a termination payment as there was no additional tax to assess in the relevant year and in any event the assessment was out of time.

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Rangers: Supreme Court confirms remuneration paid through EBT is subject to income tax

Published on 02 August 2017. By Alexis Armitage, Senior Associate

In RFC 2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) v Advocate General for Scotland [2017] UKSC 45, the Supreme Court has held that remuneration payments made into an employees' remuneration trust were earnings for income tax and NICs purposes.

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Tax update, August 2017

31 July 2017

In this update we report on the Government’s intention to use the Finance Bill (No. 2) 2017 to retrospectively implement the policies dropped from the first Finance Act 2017; amendments to the new disguised remuneration provisions in the Income Tax (Earnings and Pensions) Act 2003; and the implementation of the guidance requirement under the Criminal Finances Act 2017

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Derry – HMRC prevented from collecting tax in avoidance case

Published on 25 July 2017.

In R (ota of James Derry) v HMRC [2017] EWCA Civ 435, the Court of Appeal, in allowing the taxpayer's appeal, confirmed that HMRC is not able to ignore a claim for carried back loss relief where the taxpayer has self-assessed and computed his liability to tax.

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VAT update, July 2017

24 July 2017

In this month’s update we report on HMRC’s recent guidance on its approach to supply splitting; the Supreme Court hearing in the Littlewoods compound interest case; and the revised timetable for “Making Tax Digital”.

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New corporate criminal offence

Published on 21 July 2017. By Adam Craggs, Partner and Michelle Sloane, Partner

Failure to prevent the facilitation of tax evasion

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Oval Estates - Tribunal confirms deficiencies in invoices may not prevent VAT recovery

11 July 2017

In Oval Estates (Bath) Limited v HMRC [2017] UKFTT 403 (TC), the First-tier Tribunal (FTT) held that input tax was attributable to an identifiable supply and was recoverable despite allegations of deliberate and concealed behaviour.

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Märtin: Application directing HMRC to close its enquiry into tax avoidance scheme granted

10 July 2017

In Jörg Märtin v HMRC [2017] UKFTT 488 (TC), the First-tier Tribunal (FTT) directed HMRC to close its enquiry as it had taken no action in three years.

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Anstock - Tribunal quashes penalties imposed for failure to comply with information notice

07 July 2017

Penalties for failure to comply with an information notice issued by HMRC can only be imposed if the information notice in question is unambiguous, clear and precise.

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Tax update, July 2017

Published on 04 July 2017. By Adam Craggs, Partner

In this month’s Update we report on draft provisions for a EU wide cross-border tax planning disclosure requirement; changes to HMRC’s guidance on the WDF and announcements in the Queen’s Speech in relation to the next Finance Bill.

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Berlioz - ECJ confirms that third parties can challenge 'foreseeable relevance' of tax information exchange requests

03 July 2017

In Berlioz Investment Fund SA v Directeur de l'administration des Contributions directes (Case C-682/15), the ECJ has confirmed that a Member State's national court can review a tax information request made by another Member State in order to assess whether the requested information is 'foreseeably relevant'.

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VAT update, June 2017

Published on 29 June 2017. By Adam Craggs, Partner

In this month's update we report on proposals for the reduced VAT rate for e-publications, HMRC's first publication of VAT Notes 2017, in which it explains changes to VAT for businesses, and the latest stage in the long-running compound interest litigation involving Littlewoods.

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Rai - Tribunal quashes penalties for non-payment of PPNs and criticises HMRC's 'nitpicking pedantry'

26 June 2017

In Rai v HMRC [2017] UKFTT 0467 (TC), the First-tier Tribunal (FTT) was critical of HMRC's conduct and cancelled assessments to penalties which it had issued for failure to pay on time amounts demanded in partner payment notices (PPNs), as the statutory payment period had not expired.

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Pitcher - Tribunal finds in favour of taxpayer in APN penalty appeal

Published on 19 June 2017.

In Graham Pitcher [2017] UKFTT 0406 (TC), the First-tier Tribunal (FTT) allowed the taxpayer's appeal against a penalty for non-payment of an Accelerated Payment Notice (APN) due to defects in the APN.

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Archer: judicial review in the context of statutory tax appeals

Published on 13 June 2017. By Michelle Sloane, Partner

The High Court's judgment in R (on the application of Archer) v HMRC [2017] EWHC 296 (Admin) is one of a number of recent decisions where it has been found that the taxpayer had not challenged HMRC's decision in the correct forum.

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