Latest Development in Inverclyde
Following the hearing in the Upper Tribunal last month, a decision has now been issued, confirming the correct approach for enquiring into returns filed by limited liabilities partnerships who are found not to be trading with a view to profit.
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HMRC Guidance on COVID-19 Part 2: Statutory Residence Test
The Statutory Residence Test provides that an individual is considered to have spent a day in the UK if they are in the UK at the end of the day (midnight) subject to several exceptions, one of which is exceptional circumstances. The exception applies for 60 days only in any given tax year. During the COVID-19 pandemic, HMRC have provided example circumstances which are considered exceptional.
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HMRC Guidance on COVID-19 Part 1: Reasonable Excuse
In light of the current coronavirus pandemic, HMRC has released new guidance on taxpayer's failure to meet obligations. It has also set out the extent to which it will allow those seeking a review of, or appealing, an HMRC decision more time to do so.
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COVID-19: European Commission’s Big Plan
The coronavirus pandemic has had a great impact on countries across the world. With such a wide-ranging knock to the global economy, the European Commission released a communication on 27 May 2020, setting its plan for recovery in Europe.
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Digital Service Tax
For some years now, the OECD have been working towards an international approach to the taxation of digital businesses. Be that as it may, delay in the international implementation of this tax has resulted in many countries now enacting their own tax laws on digital services. The United Kingdom is one such country.
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Loss Relief: The Give and The Take
The introduction of the Finance Bill 2020 brings with it a relaxing of the conditions required to qualify for the share loss relief scheme. On the other hand, it also implements the Corporate Capital Loss Restrictions which were first announced in Budget 2018.
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Exit charges
As announced in July of last year, the 2020 Budget introduces a new deferred payment plan option for Corporation Tax charged on profits or gains arising from certain transactions between UK companies and EEA companies of the same group of companies.
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Reversal of Inverclyde
The 2020 Budget announced provisions to reverse last year’s FTT decision in Inverclyde. In that case, HMRC denied the appellant LLPs’ claims for Business Property Renovation Allowance on the basis that the LLPs did not carry on a business with a view to a profit.
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HMRC nudge letters
HMRC continues to fight the good fight in its quest to cut down on tax avoidance and have recently been issuing further “nudge” letters to taxpayers who may have an income source or assets producing gains overseas and consequently an undisclosed outstanding UK tax liability.
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ExxonMobil: FTT Decision Released
The FTT decision in Esso Exploration and Production UK Limited and others v HMRC, which relates to pre-2006 claims for Cross Border Group Relief, has now been released.
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