HMRC suffer rare defeat on Discovery

Ranga Nelson v The Commissioners for HMRC concerned discovery assessments and penalties for the years 2007/08 to 2012/13. HMRC had issued assessments based on the Appellant’s ‘deliberate’ behaviour in relation to the reporting of trading profit and the apparent shortfall of income compared with expenditure.

Loan charge, review and options

I have previously acknowledged the work of LCAG in securing the review of the loan charge, now due to be published no later than 30th March 2019. It was a great effort….

Complaining about HMRC – Headway or Headache?

According to the HMRC annual report and accounts of 2017-18, 69% of individuals, small businesses and agents rated their overall experience with HMRC as positive. This begs the question as to why HMRC received 77,410 new complaints? Of these complaints, HMRC claim that 99% are resolved internally.

New GAAR panel opnions

The government introduced a new General Anti-Abuse Rule (GAAR) in FA 2013 and it applies with effect from 17 July 2013. The primary objective of the GAAR is to deter taxpayers from entering into abusive arrangements and to counteract any tax advantage the abusive arrangements would otherwise achieve. GAAR comes into force when the arrangements […]

Lords Economic Affairs Committee report into The Powers of HMRC: Treating Taxpayers Fairly

Following an extensive evidence gathering exercise, their Lordships have published the latest in a series of reports into the current Finance Bill and its predecessors. This, the fourth report of the session, is particularly damning of Government policy and HMRC’s delivery of it, in dealing with the treatment of taxpayers accused of tax avoidance. Whilst […]

Voicing the 99%

“We are the 99%”, a political slogan used by the Occupy movement, refers to the concentration of income and wealth amongst the top 1% of population. It also reflects an opinion that the “99%” are paying a price for the choices of a small minority of the 1%.  Following another leak from an offshore law […]

Are all contractors equal?

Last Thursday the National Audit Office released their report into the BBC’s engagement with personal service companies (PSC’s). Given that on the same day the Government published the final Brexit Agreement that prompted several Ministerial resignations, it may be that this report largely went unnoticed. It is however worth devoting some time to reading because it gives […]

New tax year; new tax rules on disguised remuneration to bite

First published on Contractor UK- https://www.contractoruk.com/news/0013528new_tax_year_new_tax_rules_disguised_remuneration_bite.html With the Finance Act 2018 receiving Royal Assent last month, it is worth taking a closer look at the legislation that is now in force affecting contractors and anyone else who’s received loans from third parties since April 6th 1999, writes Tom Wallace, head of tax at HMRC enquiry […]

In a moment of Discovery

Isaac Newton was sitting in his garden when an apple fell on his head and in a stroke of brilliance, he formed his theory of gravity. Discoveries can be sudden and unexpected, or they can arise from a process of deliberate and careful planning induced by curiosity and/or necessity. Assessment letters under Section 29 TMA […]

WTT’s reaction to the Spring Budget

 Phillip Hammond’s first and last Spring Budget was perhaps as expected – no real surprises and no shocks, but what, if any, effect did the announcements have on the self employed? A lot of the measures that become effective for tax purposes this April were announced in the Autumn of 2016 or before. Some of […]

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