HMRC restarts paused tax investigations
Tax receipts were down by £26 billion in April as the UK’s economy was hit by the coronavirus crisis. HMRC figures show that the April tax take was £35 billion which is £26 billion (42%) less than the £61 billion received in April last year.
HMRC has it seems now quietly resumed taxpayer investigations which had been put on hold at the peak of the pandemic and have started to contact taxpayers and advisers again where there is any suspicion of non-compliant activity.
Taxpayers previously under inquiry who had a brief period of respite should now prepare for investigations to resume with aplomb and perhaps with added vigour as HMRC have a close eye on the £337billion hole in the public purse.
The DBKAG & K (CJEU) decision: an opportunity for investment funds?
On 17 June 2021, the European Court decided the joint cases K (C-58/20) and DBKAG (C-59/20) regarding whether the supply of certain services constituted the “management of special investment funds”, benefiting from the VAT exemption enshrined in Article 135(1)(g) of Council Directive 2006/112/EC.
Raising the bar: UK Supreme Court clarifies the requirements for HMRC to issue Follower Notices
On 2 July 2021, the Supreme Court delivered its judgment in R (on the application of Haworth) v HMRC  UKSC 25, finding unanimously in favour of the taxpayer and upholding the Court of Appeal’s decision to quash the follower notice issued to him.
The Danish Supreme Court decides the Fidelity case
The Fidelity case concerned claims brough by three undertakings for collective investment in transferable securities (UCITS) for the repayment of Danish withholding tax on dividends received from companies resident in Denmark between 2000 and 2009. The Supreme Court rejected the claims on the grounds that the Fidelity UCITS did not fulfil the conditions for the exemption provided by Danish law.
A yellow card for footballers and their agents……let’s bring in another match official
There has been long running tension between HMRC and the way that footballers and their agents are remunerated. As the Professional Footballers’ Association wade into the debate, Helen McGhee discusses the problems arising from agents’ fees and image rights.