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Tax Take

Blog

MDCM Ltd - Tribunal confirms that IR35 does not apply in employment status case

Published on 14 May 2018. By Alexis Armitage, Associate

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In MDCM Ltd v HMRC [2018] TC 6400, the First-tier Tribunal (FTT) has allowed the taxpayer's appeal, concluding that its contractual arrangements were such that its principal employee was not an employee of the ultimate contracting company, for the purposes of IR35.

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Sippchoice Ltd: Taxpayer can claim income tax deduction for contribution in specie to SIPP

Published on 04 May 2018. By Robert Waterson, Legal Director

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In Sippchoice Ltd v HMRC [2018] UKFTT, the First-tier Tribunal (FTT) has held that a taxpayer can obtain tax relief at source in respect of contributions made to s Self-Invested Pension Plan (SIPP) settled in the form of unquoted shares.

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Publication

Tax update May 2018

01 May 2018

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In this month’s update we report on HMRC’s recently published guidance relating DOTAS for inheritance tax, its guidance for the GAAR and a new consultation relating to tax avoidance involving Profit Fragmentation.

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Publication

Corporate tax update

01 May 2018

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Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s tax team and published quarterly.

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Blog

Onillon – Failure to take Follower Notice 'corrective action' reasonable in all the circumstances

Published on 27 April 2018. By Michelle Sloane, Senior Associate

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In Onillon v HMRC [2018] UKFTT 33 (TC), the First-tier Tribunal (FTT) allowed the taxpayer's appeal against a penalty imposed for failing to take corrective action following the issue of a Follower Notice (FN) as it was reasonable in all the circumstances for the taxpayer not to take such action.

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Publication

VAT update April 2018

Published on 24 April 2018. By Adam Craggs, Partner

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In this month’s update we report on the publication of the draft agreement on the UK’s withdrawal from the EU; the Government’s “split payment” collection model for online sales by non-UK sellers; and HMRC’s revised guidance on the cost sharing exemption.

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Blog

Hargreaves: Loyalty pays

Published on 13 April 2018. By Constantine Christofi, Associate

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In Hargreaves Lansdown Asset Management LTD v HMRC [2018] UKFTT 127 (TC) TC06383, the First-tier Tribunal (FTT) has found that loyalty bonus payments paid to investors were not "annual payments" for the purpose of section 683, ITTOIA.

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Volkswagen: CJEU provides guidance on the time limit for input VAT recovery

Published on 11 April 2018. By Nicole Kostic, Senior Associate

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In Volkswagen AG v Finančné riaditeľstvo Slovenskej republiky C-533/16, the Court of Justice of the European Union (CJEU) has held that Member States cannot impose a time limit on input tax recovery that denies claims before the taxable person is in a position to exercise its right to recover.

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Blog

Jackson : HMRC penalised in penalties case

Published on 04 April 2018. By Adam Craggs, Partner

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In Jackson v HMRC [2018] UKFTT 0064 (TC), the First-tier Tribunal (FTT) has held that HMRC had misapplied the law in respect of penalties it had issued to the taxpayer for filing late returns.

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Publication

Tax update April 2018

03 April 2018

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In this month’s update we report on HMRC’s new Code of Practice 8 guidance, the OECD’s consultation on misuse of residence and citizenship schemes to circumvent the common reporting standard.

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