Churchill Tax Advisers blogs and news
03300 577106HMRC could investigate Cryptocurrencies data
HMRC is to begin collecting data on holdings of cryptocurrencies from taxpayers it suspects of tax evasion and avoidance. With the recent surge in interest and value in cryptocurrencies, HMRC will ask for more stringent information in their 'statement of assets' which...
Football agents fees resolved by HMRC
Football agents who work on behalf of the footballer and the club they are brokering the deal with, which is called 'dual representation', have been subject to revised guidelines by HMRC. A normal transfer scenario would see the football club pay the full fee to the...
R&D Tax reliefs: Consultation
The government has an ambitious target to raise total investment in research and development to 2.4% of UK GDP by 2027. R&D tax reliefs have a key role in incentivising this investment by reducing the costs of innovation. It is therefore important to ensure that...
What the Budget 2021 means for small businesses
The Chancellor, Rushi Sunak, announced in the Spring Budget 2021, that small businesses will have CJRS and SEISS extended. Coronavirus Job Retention Scheme (CJRS) The furlough scheme has been extended to September 2021 across the UK. This means limited company...
HMRC have assigned £3.5 billion to combat covid-related fraud
Over £100m will be invested by the government for a taxpayer protection taskforce of 1,265 HMRC staff to combat the estimated £3.5bn fraudulent Covid-19 claims. The taskforce will focus on claims of the Coronvirus Job Retention Scheme (CJRS) and Self Employment Income...
Hannah and another v HMRC
The First-tier Tribunal has held, in Hannah and another v HMRC [2019] UKFTT 342 (TC) (30 May 2019), that an SDLT scheme seeking to rely on section 52 of the Finance Act 2003 (calculation of chargeable consideration in the case of annuities) failed because the annuity...
HMRC v MCX Dunlin Ltd
In HMRC v MCX Dunlin (UK) Ltd [2021] EWCA Civ 186 (17 February 2021), the Court of Appeal overturned the High Court’s decision that interest was due on repayments of liabilities to petroleum revenue tax (PRT) dating from the 1980s which had been met by crediting...
Quentin Skinner 2005 Settlement
The case of HMRC v The Quentin Skinner 2005 Settlement L and others the Upper Tribunal (UT) allowed HMRC’s appeal against a First-tier Tax Tribunal (FTT) decision, finding a number of errors in law. The UT found that section 169J of the Taxation of Chargeable Gains...
2,700 Self Assessment (SA) tax returns sent in on Christmas day
More than 2,700 customers filed their Self Assessment tax return on Christmas Day, HMRC has revealed. The peak time for completing tax returns was 14:00 to 14:59, with more than 200 customers sending their online forms. Because the Self Assessment deadline is on 31...
HMRC Advisory Fuel Rates (AFR) from 1st December
The 1st December 2020 Advisory Fuel Rates (AFR) have been cut by 1p per mile for petrol vehicles with engines of 1400-2000cc, while the diesel amount per mile for vehicles across all engine sizes remains unchanged. The rates can only be applied to: reimburse employees...
UK Budget set for 3rd March 2021
Chancellor Rishi Sunak sets the UK Budget for 3rd March 2021 Rishi Sunak has described the Budget as ‘will set out the next phase of the plan to tackle the virus and protect jobs’. Sunak become Chancellor in February 2020 after Sajid Javid's shock resignation. This...
Churchill Tax Advisers swiftly close a large tax investigation
This was a client from London that was being investigated by HMRC. The client had acquired a number of investment properties over the recent years. HMRC’s main concern was how the acquisitions were financed considering the client’s regular income not being sufficient...
Churchill Tax Advisers provide strategic capital gains tax advice for a national chain
This case came to us from another firm of accountants in London. It concerned a multi-million-pound capital gain that was made by a national chain and were looking for strategies to mitigate the tax payable. Having discussed the matter in detail with the accountants...
Business Property Relief (BPR)
Inheritance tax and business property relief You probably know that inheritance tax is due at 40% on your estate after death over and above any nil rate band available. You may know that business property relief can exempt trading assets from that tax. What you may...
Tax is on HMRC’s menu for restaurants and takeaways
It has been announced that HMRC will issue thousands of letters to businesses it believes have made incorrect or suspicious claims under the Eat Out To Help Out scheme. At the beginning of November, three people were arrested in London linked to fraudulent claims. If...
Virtual Christmas parties are eligible for the annual function exemption
Section 264 ITEPA 2003 With 2020 being a year of lockdowns, social distancing and working from home, the HMRC have made virtual company Christmas parties exempt from their annual returns. Section 264 of ITEPA 2003 allows an exemption of a company annual event hosted...
Changes to Capital Gains Tax self assessment’s
Taxpayers are being reminded that they have until 31 January 2021 to declare any profit made from selling a UK residential property, which was not their main home, during the 2019-20 financial year. Changes to how taxpayers declare and pay CGT have come into effect...
Crow Metals Limited v HMRC
This was a decision of HMRC to disallow input tax claimed by the Appellant in relation to purchases of scrap metal. The FTT decided that although the due diligence carried out by the Appellant left something to be desired the number of transactions where they had...
Dolan v HMRC
The Appellant was a UK non-resident who prior to leaving the UK had received a dividend payment of £320,000. He submitted his tax return showing the dividend but the return stated he had not been resident in the UK for the year in question. This was an error on the...
Core and Others v HMRC
This was a case where the appellant had contested HMRC’s decision to charge Capital Gains Tax. The Appellant disagreed with the decision saying that they qualified for principal private residence relief. The Appellant had bought the house, whilst previously renting...
Office Of Tax Simplification (OTS) Publishes First Capital Gains Tax (CGT) Report
The Office of Tax Simplification (OTS) has published its first report as part of the capital gains tax (CGT) review shown at the chancellor’s request. This to help ‘identify opportunities relating to administrative and technical issues as well as areas where the...
Former Owner Of BHS Has Been Jailed For 6 Years For Tax Fraud
The former owner of BHS, Dominic Chappell, has been sentenced to 6 years in prison for tax evasion. He was found guilty by a jury at Southwark Crown Court of failing to pay tax on £2.2 million of income totalling £584,000 after buying BHS for £1. Chappell, 53, enjoyed...
Churchill Tax Advisers Close A Dispute Relating To Tax Residence And Double Taxation
This case came to us following a recommendation. The client was dual resident between the UK and another European country and HMRC were seeking to charge his non-UK income to UK tax on the basis that he was tax resident in the UK. This was a complex matter involving...
Deadlines for The EU Settlement Scheme
Free movement for European nationals will come to an end on 31 December 2020 and from 1 January 2021, EU/EEA/Swiss citizens who wish to move to the UK to work and study will have to meet the requirements of the new points-based immigration system, unless they have...
Churchill Tax Advisers Advise On Complex Business Asset Relief (Entrepreneurs’ Relief) Claim
This client came to us from London and needed advice in relation to Entrepreneurs’ Relief on the disposal of his shareholding in a limited company. The technical issue with the case was that on the face of it, Entrepreneurs’ Relief was not applicable as our client had...