HMRC v Castledine: A useful guide to statutory interpretation
Claiming Entrepreneur’s Relief on a share disposal with the required 5% company shareholding failed when the Tribunal found they were considered ordinary shares so the taxpayer only owned 4.99%.
10 May 2016
HMRC v Martin: tax relief awarded in bonus clawback case
Income tax paid on a bonus payment which is later clawed back by an employer can be reclaimed by the taxpayer, but only in certain circumstances.
13 November 2014
HMRC tax assessments: time limits increased in relation to offshore matters
The Finance Bill 2018-19 increases tax assessment time limits for non-deliberate offshore non-compliance, allowing HMRC to open assessments up to 12 years after the relevant tax year.
24 July 2018
HMRC publishes new Spotlight 32
HMRC "spotlights" represent its list of targeted tax avoidance schemes which taxpayers and employers need to be aware of. The latest spotlight is part of HMRC's focus on "managed service companies".
17 August 2016
HMRC ordered to suspend penalty for inaccuracy in tax return
In Eric Eastman v HMRC [2016] the First Tier Tribunal ruled that HMRC was unreasonable to refuse to suspend a penalty for a careless inaccuracy in a taxpayer's self-assessment return.
29 September 2016
Holding over – a major risk for tenants as well as landlords
A recent ruling in Barclays Wealth Trustees (Jersey) Ltd v Erimus Housing Ltd [2013] EWHC 2699 dealt us a new concept – that holding over can be a major risk for tenants as well as landlords.
03 October 2013
HMRC found to have made mistakes in almost half of all cases reviewed/appealed in 2013/14
HMRC's Reviews and Appeals - 2013-14 contains statistics showing the outcome of reviews and appeals against HMRC tax decisions for the year 1 April 2013 to 31 March 2014.
22 January 2015
Holding over – less risky than we thought?
The Court of Appeal has allowed the tenant’s appeal in the case of Barclays Wealth Trustees (Jersey) Limited v Erimus Housing Limited. T
26 March 2014
“Hole in the wall” ATMs at risk after business rates decision
"Hole in the wall" style ATMs are to pay separate business rates following an Upper Tribunal decision which may impact free cash machines in supermarkets, petrol stations and convenience stores.
26 April 2017
HMRC anti-avoidance task-force – tackling “hidden wealth” in London
HM Revenue & Customs' HMRC has recently announced a task-force targeting “hidden wealth” in London and East Anglia.
25 February 2014
How systematic is systematic? HMRC unable to answer FOI request on the Lagarde List
Following HMRC's press release regarding its use of the Lagarde List to 'assess, collect enforce and prosecute tax offences', Burges Salmon made a Freedom of Information request.
20 May 2015
How sacred is the day of rest?
An employee’s belief that they should not work on a particular day does not have to be a core part of their religion in order to fall under religious discrimination legislation.
11 December 2013