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Tax Bites - June 2020

Published on 04 June 2020

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 you would like more information on, or if you have any questions or feedback, please let us know or get in touch with your usual RPC contact.


Spotlight 55 - umbrella company warning

On 27 April 2020, HMRC published Spotlight 55, setting out further warnings and advice on the use of umbrella companies. Read more

DAC 6 delay

On 8 May 2020, the European Commission published a proposal to amend Directive 2011/16/EU (the Directive), delaying disclosure deadlines imposed by Directive (EU) 2018/822 (DAC 6), by three months. Read more

Temporary exemption for Covid-19 employee expenses

On 13 May 2020, the Financial Secretary to the Treasury, Jesse Norman, stated that a temporary exemption from income tax and National Insurance contributions (NICs) will be introduced for expenses reimbursed by an employer to an employee where two conditions are satisfied. Read more


Case reports

Henkes - Tribunal determines domicile on application for closure notice

In Henkes v HMRC [2020] UKFTT 159 (TC), the First-tier Tribunal (FTT) decided that it has jurisdiction to determine mixed questions of fact and law on an application for a closure notice and appeal against an information notice. Read more

Looney - Termination payments were trading receipts

In Looney & Anor v HMRC [2020] UKUT 0119 (TCC), the Upper Tribunal (UT) has dismissed an appeal against the FTT's decision that a termination payment and other payments made under a contract entered into by a partnership to provide management training, were trading receipts of the partnership. Read more

Coyle - Upper Tribunal refuses permission to appeal out of time

In Michael Coyle t/a Coyle Transport v HMRC [2020] UKUT 0113 (TCC), the UT set aside the decision of the FTT, but reached the same conclusion as the FTT and refused the taxpayer permission to appeal out of time. Read more


And finally...

On 18 March 2020, following its interim ruling that "Cum­Ex" trading was illegal, a German court found two former London­ based investment bankers guilty of tax evasion offences in the first criminal trial related to Cum­Ex trades in a landmark ruling which could lead to hundreds more cases. Read more