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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 employment taxes and VAT.

Subsistence expenses wrongly treated as tax-free for temporary workers
  • Dec 2025
The Court of Appeal (CA) dismissed the taxpayer’s appeal on the basis subsistence expenses were wrongly treated as tax-free for temporary workers with no permanent workplace...
Upper Tribunal win for HMRC on employment income
  • Dec 2025
The Upper Tribunal (UT) has found that an amount paid to a taxpayer after ceasing employment was taxable as employment income....
Supplies of nursing staff
1st Alternative Medical Staffing Ltd (FAMS) supplied nurses and care assistants to NHS and private hospitals and care homes. FAMS accounted for VAT on their commission only, not on the amount paid to the nurses/care assistants, on the basis that FAMS was acting as agent...
VAT and hospital car parking
Northumbria Healthcare NHS Foundation Trust considered that its provision of paid-for hospital car parking was not chargeable to VAT. HMRC disagreed, and the First-tier Tribunal (FTT) and then the Upper Tribunal dismissed the Trust’s appeals...
Import VAT recovery by a non-owner
TSI Instruments Limited imported scientific equipment into the UK for repair and servicing. TSI claimed the import VAT it paid on importation as input tax. HMRC considered that, in accordance with its internal manual VIT13300, TSI was not entitled to input tax recovery...
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Personal tax

This month covers property tax.

Summerhouse not an independent dwelling
  • Dec 2025
The First-tier Tribunal (FTT) has found that a summerhouse with a lavatory was not a separate dwelling. Although it was used by the family, it was not suitable for use as a dwelling on its own due to the lack of a shower or bath.
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Tax compliance and investigations

This month covers penalties. 

Reliance on accountant not a reasonable excuse
  • Dec 2025
The First-tier Tribunal (FTT) found that while the taxpayer had initially taken sufficient steps to file his tax returns, he should have made more enquiries when penalty notices began to arrive...
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Tax administration

There are no updates this month.

Tax payments and repayments: Taxpayers fail to recover loan charge payments to HMRC
  • Oct 2025
The Upper Tribunal (UT) has found that taxpayers who used the Disguised Remuneration Repayment Scheme were not entitled to a refund, as HMRC would have had power to recover the amounts...
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