Andrew Levene

Sep 11, 2023 | taxjournal.com | Tom Wallace |David Whiscombe |Andrew Levene |Carrie Rutland

Regardless of your area of tax expertise, it's likely that you've come across concerns about the misuse of the R&D tax credit system. Whether it be through claims that are pushing at the boundaries of the definition of R&D, or outright fraudulent endeavours, it is clear HMRC have become overwhelmed while trying to police the regime. As a result, they are now seeking to change their approach to how they tackle compliance within this space.

Sep 7, 2023 | taxjournal.com | Mike Lane |Zoe Andrews |David Whiscombe |Andrew Levene

Tax and the City review for September © Copyright LexisNexis 2023. All rights reserved. 7 September 2023 Speed read The Upper Tribunal in JTI Acquisitions dismisses the taxpayer’s appeal, agreeing with the First-tier Tribunal’s conclusions on the application of the unallowable purpose rule whilst identifying some non-material errors in its approach.

Sep 7, 2023 | taxjournal.com | David Whiscombe |Andrew Levene |Carrie Rutland |Tom Gilliver

Insurance companies – structural assetsHMRC consultation on draft regulations: The Insurance Companies (“The Long-term Business Fixed Capital”) Regulations 2023 on how to specify which assets are to be treated as structural assets of an insurance company’s long-term business. This is significant because the income and gains from structural assets are excluded from trading profits.

Sep 7, 2023 | taxjournal.com | David Whiscombe |Andrew Levene |Carrie Rutland |Tom Gilliver

The facts were simple enough. Mr and Mrs England ([2023] UKFTT 313 (TC), as reported in Tax Journal, 14 April 2023) had borrowed money from their company through having overdrawn directors’ loan accounts. The company became insolvent and the liquidator, apparently recognising the impossibility of recovering the full amount of the debt, did a deal.

Sep 7, 2023 | taxjournal.com | David Whiscombe |Andrew Levene |Carrie Rutland |Tom Gilliver

The tracker is split into three parts: • cases subject to an appeal which contains those cases that are currently subject to an appeal • cases potentially subject to an appeal which contains those cases that have received judgments and could still appeal these decisions • finalised tax cases which contains those cases that are no longer subject to an appeal Cases subject to an appeal This section of the tracker shows those cases that are currently subject to an appeal. Names of parties Court...