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Practical Points

Every month, the Tax Faculty publishes short, practical pieces of guidance to help agents and practitioners in their day-to-day work.

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Business tax

This month covers corporation tax; partnership taxation; and VAT.
Corporation tax: FTT dismisses taxpayer’s appeal on loan relationships ‘unallowable purpose’ rule
  • Dec 2024
The First-tier Tribunal (FTT) has dismissed a taxpayer’s appeal in the corporation tax case of Syngenta Holdings Limited v HMRC concerning the loan relationships unallowable purpose rule (s441 and 442, Corporation Tax Act 2009)...
Corporation tax: LLP and corporate members related for amortisation rules
  • Dec 2024
The Upper Tribunal (UT) has upheld the First-tier Tribunal (FTT) decision that a Limited Liability Partnership (LLP) is related to its corporate members even though it is not a company. As a result, relief for amortisation for assets acquired from those companies was denied...
Partnership taxation: FTT allows taxpayers’ appeal on whether an LLP was ‘carrying on a business’
  • Dec 2024
The First-tier Tribunal (FTT) has allowed the taxpayers’ appeal in the Limited Liability Partnership (LLP) case of GCH Corporation Ltd and others v HMRC. The case considers s59A, Taxation of Chargeable Gains Act 1992, which...
VAT: Penalties for inward diversion fraud
  • Dec 2024
In October 2022, Sintra Global Inc (Global) and Mr Parul Malde were successful in an appeal to the First-tier Tribunal (FTT) against HMRC decisions and assessments relating to the non-payment of VAT and excise duties and related penalties...
VAT: Zero rating of exported goods
  • Dec 2024
Procurement International Ltd (PIL) was a reward recognition programme fulfiller. It supplied goods to businesses that ran reward recognition programmes (reward programme operators – RPOs) on behalf of their customers...
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Personal tax

This month covers income tax; and inheritance tax.
Income tax: Interim dividend was taxable on receipt
  • Dec 2024
The Upper Tribunal (UT) has upheld a First-tier Tribunal (FTT) decision that an interim dividend paid at different times to two shareholders for tax reasons was taxable on each at the date received. HMRC had sought...
Inheritance tax: Business relief not available on furnished offices
  • Dec 2024
The First-tier Tribunal (FTT) has found that serviced offices were still an investment, not carrying out a trading activity. The decision involved a careful analysis of the exact activities, as well as case law, but ultimately determined...
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More in personal tax

Tax compliance and investigations

There are no updates this month.
Penalties: Reasonable excuse
  • Nov 2024
A new penalties regime has applied from 1 January 2023 to the late submission and late payment of VAT returns. Under this regime, a taxpayer may not be liable to a penalty if they...
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More in tax compliance and investigation

Tax administration

There are no updates this month.
Agents and HMRC: Checking marriage allowance claims using PAYE codes
  • Dec 2023
Agents are able to check whether a client has an enduring marriage allowance claim using the client’s PAYE code. PAYE codes ending in the suffix ‘N’ indicate that an election is in place to transfer part of the personal allowance to a...
Tax returns: Relying on HMRC guidance
  • Nov 2023
Some advisers may have noticed an increase in the number of changes to HMRC’s guidance – in particular changes to articles in Agent Update and Employer Bulletin...
Making tax digital: Manual MTD registration required for some new VAT registrations
  • Oct 2023
When registering for VAT through HMRC’s VAT registration service, businesses should be automatically signed up to making tax digital (MTD). However, in some exceptional cases, the MTD registration is not being processed...
Tax payments and repayments: HMRC guidance on reducing self assessment repayment delays
  • Oct 2023
Self assessment repayments can be delayed at three different stages: 1. A delay to the processing of the return, form, or amendment that generates the repayment. 2. A repayment inhibitor is triggered. 3. The repayment is...
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More in tax administration

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