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Jan 9, 2025 | 
taxjournal.com | David Whiscombe |Benjamin Wonnacott |Andrew Constable
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Jan 8, 2025 | 
taxjournal.com | David Whiscombe |Benjamin Wonnacott |Andrew Constable
John-Paul Marks is to take over as HMRC
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Jan 7, 2025 | 
taxjournal.com | David Whiscombe |Benjamin Wonnacott |Michael Sherry |Andrew Constable
In M R Currell Ltd v HMRC [2024] UKUT 404 (TCC) (6 December 2024) the Upper Tribunal (UT) considered an appeal of the taxpayer company against a decision of the First-tier Tribunal (FTT) that a director and shareholder of the taxpayer company received taxable earnings in circumstances where the company had made a contribution to an employee benefit trust (EBT) which then subsequently loaned an equivalent amount to the shareholder director.
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Jan 7, 2025 | 
taxjournal.com | David Whiscombe |Benjamin Wonnacott |Michael Sherry |Andrew Constable
In JTC Employer Solutions Trustee Ltd and others v W Garnett and others[2024] EWHC 3128 (Ch) (9 December 2024) the High Court (HC) permitted rescission in relation to Employee Benefit Trust appointments to sub-trusts with the result that IHT in the region of £7m was avoided. The HC decided that the mistake in creating sub-trusts was sufficiently grave to render it unconscionable to leave the mistaken dispositions uncorrected.
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Jan 7, 2025 | 
taxjournal.com | David Whiscombe |Benjamin Wonnacott |Andrew Constable |Tanja Velling
The announcement of a Spring Statement (rather than another Budget) on 26 March 2025 chimes with the promise of ‘predictability, stability and certainty’ in the UK government’s corporate tax roadmap (which had sat uneasily with the surprise announcement of an increase in employers’ NICs at the Autumn Budget). It also delivers on Labour’s commitment to one major fiscal event a year, although the media has already started to speculate whether the Chancellor may have to announce further tax rises.
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Jan 7, 2025 | 
taxjournal.com | Oliver Marre |David Whiscombe |Benjamin Wonnacott |Andrew Constable
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Jan 6, 2025 | 
taxjournal.com | David Whiscombe |Benjamin Wonnacott |Andrew Constable
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Jan 6, 2025 | 
taxjournal.com | David Whiscombe |Benjamin Wonnacott |Andrew Constable
The Chancellor has asked the Office for Budget Responsibility (OBR) to produce an economic and fiscal forecast which will be published on 26 March 2025. This is in line with the Budget Responsibility and National Audit Act 2011 which requires the OBR to produce two forecasts each financial year. Although the Chancellor will also make a statement to Parliament this is not a Budget. The press release confirms that the Chancellor remains committed to one ‘major’ fiscal event a year.
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Jan 6, 2025 | 
taxjournal.com | David Whiscombe |Benjamin Wonnacott |Andrew Constable
The Public Bill Committee is expected to begin its scrutiny of Finance Bill 2025 on Tuesday 28 January 2025 according to a ‘call for evidence’ issued on 20 December 2024. The Committee is scheduled to complete its work by Tuesday 4 February 2025 at the latest. Comments are invited on the Finance Bill with the usual recommendation that submissions are made sooner rather than later. On 19 December 2024 the first set of Government amendments was published for debate by the Public Bill Committee.
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Jan 6, 2025 | 
taxjournal.com | David Whiscombe |Benjamin Wonnacott |Andrew Constable
On 17 December 2024 the National Insurance Contributions (Secondary Class 1 Contributions) Bill was debated by a Committee of the whole House in the House of Commons. No amendments were made to the Bill (which remains as introduced) and it received its Third Reading. The Bill has now moved to the Lords and received Second Reading on Monday 6 January 2025. Lords Committee Stages had yet to be scheduled.
