Tax Bites - April 2021
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
As always, if there are any areas on which you would like more information (or if you have any questions or feedback), please let us know or get in touch with your usual RPC contact.
HMRC updates its guidance on compliance checks
HMRC has updated its guidance with more information on how agents and taxpayers can assist it with compliance checks. Read more
HMRC issues briefing paper on how it will support organisations to comply with changes to the off-payroll working rules (IR35)
HMRC issues briefing paper on how it will support organisations to comply with changes to the off-payroll working rules (IR35). Read more
HMRC has issued Spotlight 57, in which it confirms that it is aware of an arrangement where a business may enter into an agreement with a trust and claim to have sold the rights to its future revenue to the trust. The revenue is not included in the business’s accounts (so no tax is paid on it) and the transfer of funds to the trust is not disclosed to HMRC. In the view of HMRC, this arrangement is a contrived form of tax avoidance arrangement and it will challenge anyone promoting such arrangements and investigate the tax affairs of all users. Read more
Regulations published amending capital gains treatment of UK property-rich collective investment vehicles
Regulations have been made amending the taxation of non-UK investors in UK property-rich collective investment vehicles (CIVs). Read more
Government publishes its response to the House of Lords Economic Affairs Finance Bill Sub-Committee report on whether new powers for HMRC are fair and proportionate
The UK government has published its response to a report produced by the House of Lords Economic Affairs Finance Bill Sub-Committee on whether new powers for HMRC are fair and proportionate. Read more
In HMRC v SSE Generation Ltd  EWCA Civ 105, the Court of Appeal (CA) has dismissed HMRC's appeal and agreed with the Upper Tribunal's (UT) decision that expenditure on parts of a hydroelectric power scheme was eligible for capital allowances. Read more
Ditton – HMRC cannot issue daily late filing penalties retrospectively
In D & G Ditton Ltd v HMRC  UKFTT 489 (TC), the FTT has held that daily late filing penalties, where notice was given by HMRC to the taxpayer after the period in respect of which the penalties were issued, were void. Read more
Atholl House Productions - BBC presenter wins IR35 case
In HMRC v Atholl House Productions Ltd  UKUT 0037 (TCC), the UT has held that IR35 did not apply to a presenter who provided services to the BBC through a personal service company. Read more
It was International Women's Day on 8 March 2021, and to mark the occasion we commissioned a special episode of our Taxing Matters podcast, which featured five successful women who have encouraged diversity and inclusion in the workplace.
Our guest speakers all come from very different backgrounds and include a global tax correspondent at the FT, a former Tax VP at Sony and the owner of a successful consulting group. They each share the challenges they have faced at work and address a range of topics including juggling family life, being overlooked and suffering imposter syndrome.
You can listen to our podcast here.