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Jan 7, 2025 | 
taxjournal.com | Oliver Marre |David Whiscombe |Benjamin Wonnacott |Andrew Constable
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Nov 1, 2024 | 
taxjournal.com | Duncan Weldon |Robert Waterson |Ray McCann |Oliver Marre
The first Budget of a new government is always a big moment a chance to set out a new direction. Rachel Reeves did just that at her first fiscal event embarking on an economic and political gamble that what Britain wants and needs is a much larger state. Taxes borrowing and government spending all increased markedly.
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Nov 1, 2024 | 
taxjournal.com | Ray McCann |Robert Waterson |Duncan Weldon |Oliver Marre
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Nov 1, 2024 | 
taxjournal.com | Robert Waterson |Duncan Weldon |Ray McCann |Oliver Marre
As to tax controversy and dispute resolution this Budget presents a mixed picture. Changes in existing regimes often cause uncertainty and confusion particularly if there is a gap between the enactment of legislation and HMRC Guidance being updated. Three areas of change which seem likely to lead to an increase in disputes are (1) the abolition of the non-domicile status; (2) substantive changes to the R&D tax regime; and (3) the intention to close down the scope of charity tax reliefs.
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
The GAAR Advisory Panel has issued an opinion on arrangements which sought to reward a company’s director in a way ‘that would not be any form of remuneration’. This involved creating an obligation to make pension payments to the individual transferring that obligation to a third party and paying the third party for accepting that obligation. In essence the full amount that otherwise would have been paid to the individual was instead routed via the third party.
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
Chancellor Rachel Reeves delivered her first Budget on 30 October 2024. Together with the headline increase in employer NICs the Chancellor’s changes to CGT rates and reform of IHT reliefs are expected to impact on businesses with carried interest also brought into focus.
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
In GCH Corporation Ltd and others v HMRC [2024] UKFTT 922 (TC) (17 October), the FTT allowed the taxpayers’ appeals against capital taxes assessments relating to a transfer of loan notes to a limited liability partnership by its members. Gregory Hutchings (GH), who worked in senior positions at Tomkins PLC (Tomkins) until 2000, was the trustee of three family trusts (‘the trusts’).
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
In S Lefort v HMRC [2024] UKFTT 926 (TC) (17 October) the FTT upheld HMRC’s decision to revoke the taxpayer’s certificate of fixed protection under the legislation reducing the pension schemes lifetime allowance in 2014. The taxpayer was an airline pilot employed by Virgin Airlines. He had a self-invested pension plan (SIPP) into which he and Virgin made contributions. He left the company in February 2014 making a final contribution to the plan and obtained a Fixed Protection 2014 certificate.
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Oct 31, 2024 | 
taxjournal.com | Andrew Marr |Chris Etherington |Oliver Marre
HMRC have decided to disband the Joint Forum on Expatriate Tax and NICs (the Expat Forum) informing members that the ‘group’s effectiveness has reduced with an increasingly long list of unresolved issues’ and suggesting that many of the live issues would be more suitably dealt with via other channels.
