The Loan Charge, Jesse Norman and Empty Words

Loan Charge distress In the second half of 2018, the House of Lords Economic Affairs Committee took considerable pains to review the provisions of the then Finance Bill and produced a report (see link below). This report benefited from hearing evidence, written and face to face, from a number of experts and those working in […]

Finance Bill 2019-20: IR35 Off payroll working reform

11th July 2019 saw the long-awaited documents bringing into legislation the extension of the off payroll working rules from the public sector into the private and third sectors. A policy paper, a response to the consultation process, and draft legislation were published today. In this instance, experience has triumphed over hope and we will see […]

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.

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 […]