The following Owner-Managed Businesses guidance note Produced by Tolley provides comprehensive and up to date tax information covering:
These are our brief notes and thoughts on cases published in the last week or so which caught our eye and are likely to be of particular interest to tax practitioners. Full case reports and commentary on most of these cases will be included within our normal reference sources in the coming weeks.
This is yet another appeal against a penalty for failure to notify liability to the high-income child benefit charge. It is worth a brief note because the taxpayer was successful on the basis that it was accepted that he had a reasonable excuse.
HMRC had sent him ‘nudge’ letters reminding him of the liability, but he had not received them. Often in tribunals, taxpayers claim non-receipt of letters but do not put forward any evidence to support their argument. Proving a negative, that you have not received something, is difficult, but here the taxpayer provided evidence, including a photograph of previous delivery problems. The post office had frequently confused his property with a similar sounding address a mile away. This was enough to tip the balance in his favour. He acted promptly when he did ultimately receive a letter from HMRC about the liability.
As ever, evidence rather than assertion is the key to success in tribunal hearings.
This is a comparatively rare example of an employee being able to obtain tax relief for at least some of the cost of accommodation and is therefore important. Travel and subsistence is always a difficult area of tax law.
The taxpayer was an experienced dental surgeon living with his family in Southampton. He wanted to become a maxillofacial surgeon and this involved taking a full-time training position in London for four years. Initially, he tried to commute from Southampton to London but that was untenable as it left him exhausted and unable to treat his patients properly. He, therefore, rented a property
**Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason.
Access this article and thousands of others like it free for 7 days with a trial of TolleyGuidance.
Read full article
Already a subscriber? Login
Almost all companies will have some loan relationships. However, some items that are commonly assumed to be loan relationships are not (eg outstanding consideration for the sale / purchase of property and inter-company balances relating to unpaid amounts for goods or services, in each case where
IntroductionUK tax must be withheld on UK payments including:•interest•royalties•rental incomeUK withholding tax may be reduced under the provisions of a double tax treaty (DTT). Prior to 1 June 2021, payments of interest and royalties made to EU resident associated companies were also exempt from
What is transfer pricing?Transfer pricing is the prices at which an enterprise transfers either physical goods, intangible property or services, including financing arrangements, to associated enterprises. Generally, enterprises are associated if there is direct or indirect control by one of the
This note applies to transactions whilst the Great Britain was a member of the EU and during the transition period that ended on 31 December 2020. For information on Northern Ireland see the Northern Ireland topic. Triangulation is an EU simplification measure that was introduced in order to reduce