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.

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.

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 […]

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 […]

Summary of the Rangers Case to Date

Introduction With a recent announcement from the Supreme Court that the long-awaited judgement for RFC 2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) v Advocate General for Scotland (Respondent) (more commonly known as the Rangers Case) will be known on 5th July 2017, it is worth recapping on the salient points of the […]

Tackling Disguised Remuneration

Two Technical Updates on ‘tackling disguised remuneration’ have been released [i] on 20th March 2017. Both deal with the operation and consequences of the proposed tax charge on unpaid loan balances at 5th April 2019, a 20 year retrospective law. Of particular interest is an amendment to the 2019 charge to account for contractor arrangements […]

Transferring PAYE liability from an employer to an employee

 An interesting case here where HMRC tried and failed to transfer a PAYE liability from an employer to an employee. http://financeandtax.decisions.tribunals.gov.uk//judgmentfiles/j9262/TC05285.pdf The law at the heart of the dispute was Regulation 72 of the Income Tax (Pay as you Earn) Regulations 2003, SI 2003/2682. They also included the NIC equivalent under regulation 86 of the Social […]

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