Mike Lane

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Articles

Tax and the City review for January 2025

Jan 15, 2025 | taxjournal.com | Mike Lane |Zoe Andrews |Tanja Velling |David Whiscombe

The Court of Appeal in Refinitiv Ltd and others v HMRC [2024] EWCA Civ 1412 dismissed the taxpayer’s judicial review claim seeking to quash or declare unlawful a diverted profits tax (DPT) notice. Refinitiv a UK resident company in the Thomson Reuters group had argued that the DPT notice issued by HMRC in 2018 was incompatible with an advance pricing agreement (APA) entered into for the period from 2008 to 2014.
HMRC are not appealing decisions on R&D subsidies and contracting out

Jan 6, 2025 | taxjournal.com | David Whiscombe |Benjamin Wonnacott |Michael Sherry |Mike Lane

HMRC have confirmed to the CIOT that they have decided not to appeal the FTT decisions on contracted-out and subsidised R&D in Collins Construction Ltd v HMRC [2024] UK FTT 951 (TC) and Stage One Creative Services v HMRC [2024] UKFTT 1059 (TC). Those cases related to the pre-2024 R&D regime for SMEs but will be of particular interest to advisers who have ongoing cases involving questions around subsidies and sub-contracting. HMRC say they intend to publish guidance in February 2025.
HMRC are not appealing decisions on R&D subsidies and contracting out

Jan 6, 2025 | taxjournal.com | David Whiscombe |Benjamin Wonnacott |Michael Sherry |Mike Lane

HMRC have confirmed to the CIOT that they have decided not to appeal the FTT decisions on contracted-out and subsidised R&D in Collins Construction Ltd v HMRC [2024] UK FTT 951 (TC) and Stage One Creative Services v HMRC [2024] UKFTT 1059 (TC). Those cases related to the pre-2024 R&D regime for SMEs but will be of particular interest to advisers who have ongoing cases involving questions around subsidies and sub-contracting. HMRC say they intend to publish guidance in February 2025.
No new side hustle tax, HMRC confirm

Dec 5, 2024 | taxjournal.com | David Whiscombe |Benjamin Wonnacott |Michael Sherry |Mike Lane

HMRC are attempting to make clear that although new reporting requirements apply for online platform operators from January 2025 the tax position for individuals who sell items (or services) on those platforms remains unchanged. This appears to address widespread confusion around a ‘side hustle tax’ that had been reported in the mainstream media earlier in 2024 after the separate reporting rules for platform operators had been announced.
No new side hustle tax, HMRC confirm

Dec 5, 2024 | taxjournal.com | David Whiscombe |Benjamin Wonnacott |Michael Sherry |Mike Lane

HMRC are attempting to make clear that although new reporting requirements apply for online platform operators from January 2025 the tax position for individuals who sell items (or services) on those platforms remains unchanged. This appears to address widespread confusion around a ‘side hustle tax’ that had been reported in the mainstream media earlier in 2024 after the separate reporting rules for platform operators had been announced.
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC

Dec 5, 2024 | taxjournal.com | David Whiscombe |Benjamin Wonnacott |Michael Sherry |Mike Lane

The Exchequer Secretary to the Treasury James Murray MP said he committed to the timeframe for Making Tax Digital for Income Tax Self-Assessment following ‘robust’ conversations with HMRC in the summer.
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC

Dec 5, 2024 | taxjournal.com | David Whiscombe |Benjamin Wonnacott |Michael Sherry |Mike Lane

The Exchequer Secretary to the Treasury James Murray MP said he committed to the timeframe for Making Tax Digital for Income Tax Self-Assessment following ‘robust’ conversations with HMRC in the summer.
Time for a replacement wealth tax?

Dec 4, 2024 | taxjournal.com | Michael Sherry |David Whiscombe |Benjamin Wonnacott |Mike Lane

Why is the farming community so upset by the APR and BPR changes? Most of the reasons given are real, but I think the real reason is that inheritance tax is really hated. It might be different, maybe, if the entry level were way higher and the entry rate were way lower (compare the US where the rates start at 18% on an estate of one £11m rising progressively to a maximum of 40% on the taxable slice over $1m above the threshold).
Pension ‘megafund’ reforms: how does tax fit in?

Dec 4, 2024 | taxjournal.com | Benjamin Wonnacott |David Whiscombe |Michael Sherry |Mike Lane

The Government’s ambitious post-election pensions investment review is progressing with impressive speed.
R Grint v HMRC

Dec 4, 2024 | taxjournal.com | David Whiscombe |Benjamin Wonnacott |Michael Sherry |Mike Lane

In R Grint v HMRC [2024] UKFTT 956 (TC) (25 November) the FTT found that the sale of occupation income avoidance rules applied to a capital sum arising on incorporation. Though there were commercial reasons for incorporation reduction of tax was still a main motive and the anti-avoidance provisions were engaged despite an error in HMRC’s £1.8m closure notice assessment.