IR35 reform will reshape the market

The agency The shift of the decision maker for determining IR35 status, post April 2020 is going to have deep and permanent repercussions. Until that date, the decision as to status lies with the contractor. If that decision is ultimately incorrect and more tax is due, the contractor is liable. Post April 2020, the end […]

Fairness and Jesse Norman 2011 v. 2019

The Financial Secretary to the Treasury, Jesse Norman MP, is not long in his post and yet he is already overwhelmed. Since having asked for information as to the impact of the loan charge his inbox has been swamped with personal stories. We have seen some of these stories; a sound night’s sleep does not […]

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.

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.

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 […]

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 […]