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3 weeks ago | 
labourlist.org | Parmjit Dhanda |Jeremy Mindell
If you meet a powerful person, ask them five questions: “What power have you got? Where did you get it from? In whose interests do you exercise it? To whom are you accountable? And how can we get rid of you?”Whilst your co-authors to this article are not ‘Bennites’ we do agree that the late Tony Benn MP, firebrand minister from the 1970s Labour government, had a point when he made that statement. Certainly, when it comes to The Office for Budget Responsibility (OBR).
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Feb 26, 2025 | 
taxjournal.com | Elena Rowlands |Tom Margesson |Helen Buchanan |Jeremy Mindell
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Feb 19, 2025 | 
taxjournal.com | Elena Rowlands |Tom Margesson |Helen Buchanan |Jeremy Mindell
HMRC and the Department for Business and Trade (DBT) have jointly launched a 12-week consultation on electronic invoicing which the UK government hopes will reduce paperwork for businesses and enhance productivity. E-invoicing will be particularly relevant to VAT in terms of potentially improving the accuracy of VAT returns and reducing the VAT gap. The consultation closes on 7 May 2025.
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Feb 19, 2025 | 
taxjournal.com | Elena Rowlands |Tom Margesson |Helen Buchanan |Jeremy Mindell
The financial thresholds for determining the size of a company under the off-payroll working rules are set to increase from 6 April 2025. The substantive changes to the turnover and balance sheet thresholds were made by SI 2024/1303 to Part 15 of the Companies Act 2006 with corresponding changes to the rules for LLPs – the aim being to provide lighter-touch reporting and audit requirements for more companies.
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Feb 19, 2025 | 
taxjournal.com | Elena Rowlands |Tom Margesson |Helen Buchanan |Jeremy Mindell
HMRC have published a GAAR Advisory Panel opinion dated 29 October 2024 on further arrangements which sought to use the creation and transfer of pension obligations. In this particular set of circumstances pension benefits were awarded to two directors of a company. Those pension obligations were then transferred from the company to the two directors personally – with each director assuming the pension obligation for the other in return for a sum of money paid by the company to each director.
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Feb 12, 2025 | 
taxjournal.com | Elena Rowlands |Tom Margesson |Helen Buchanan |Jeremy Mindell
HMRC have said they will reverse their approach on the targeted anti-avoidance rule (TAAR) under the salaried members rules (ITTOIA 2005 ss 863A–863G) as announced in February 2024 in which the department said they would apply the TAAR where members made a top-up capital contribution in order to avoid meeting Condition C of the rules.
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Feb 12, 2025 | 
taxjournal.com | Elena Rowlands |Tom Margesson |Helen Buchanan |Jeremy Mindell
In S Fitzgerald and another v HMRC [2025] UKFTT 89 (TC) (24 January) the FTT dismissed an appeal against a closure notice disallowing SDLT multiple dwellings relief (MDR) in respect of the purchase of a property which included a main house and an annexe. In 2020 the taxpayers purchased a property consisting of a five-bedroom detached house an annexe garage and car port. The annexe had its own kitchen living room bedroom and bathroom.
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Feb 12, 2025 | 
taxjournal.com | Elena Rowlands |Tom Margesson |Helen Buchanan |Jeremy Mindell
In Lloyds Asset Leasing Ltd v HMRC [2025] UKFTT 57 (TC) (20 January) the First-tier Tribunal (FTT) dismissedthe taxpayer’s appeal against HMRC’s disallowance of its cross-border group relief (CBGR) claim. The appellant Lloyds Asset Leasing Ltd (LAL) was one of 100 subsidiaries of Lloyds Banking Group (LBG) that claimed CBGR in respect of losses incurred by Bank of Scotland Ireland Ltd (BOSI).
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Feb 12, 2025 | 
taxjournal.com | Elena Rowlands |Tom Margesson |Helen Buchanan |Jeremy Mindell
In Sarabande v HMRC [2025] UKFTT 93 (TC) (30 January) the FTT decided that Sarabande (‘SB’) did not make an exempt supply of land to its subsidiary and therefore HMRC’s denial of input tax incurred on acquiring and refurbishing a property was invalid. SB is registered charity and the owner of a long leasehold in a property in central London. Suture Inc Ltd (‘SIL’) is a wholly owned subsidiary of SB and not registered for VAT.
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Feb 5, 2025 | 
taxjournal.com | Helen Buchanan |Jeremy Mindell |David Whiscombe
The UK is suspending the Russia and Belarus Double Tax Treaties from April 2025. Both countries had previously suspended material provisions of their Double Taxation Conventions with the UK and have not responded to the UK request to come back into compliance with their international legal obligations. Therefore the UK will revoke the legislation which gives effect to the Conventions in UK law.
