Technical

Technical

The call for evidence was initiated by the (last) government to consider (i) whether the tax rules for expenses of employment need to change to reflect changes in employment engagement practices, (ii) whether the rules and their administration can be made simpler and clearer, and (iii) why there has been a 25% increase since 2009-10 in claims to HMRC from employees for tax relief on non-reimbursed expenses. In their submissions to the call for evidence, the ATT, CIOT and LITRG suggest that the existing system is not broken, per se, but could certainly be improved.

Technical

The CIOT, LITRG and ATT have all responded to HMRC’s latest consultation on late submission penalties and late payment penalty interest.

Technical
1 August 2017

The CIOT commented on the Public Discussion Draft on Base Erosion and Profit Shifting (BEPS) Action 8 – Implementation Guidance on Hard-to-Value Intangibles published by the OECD in May 2017.

Technical
1 August 2017

The government set out their programme for the new parliamentary session on 21 June. Unusually, the new session is scheduled to last two years rather than the usual one and is likely to be dominated by Brexit legislation. Among the 27 Bills and draft Bills the following will be of particular interest to tax professionals.

Technical
1 July 2017

LITRG explains changes this year to HMRC’s processes for renewing and checking tax claims.

Technical
1 July 2017

The CIOT has responded to HMRC proposals to explore a domestic VAT reverse charge for the provision of construction sector services.

Technical
1 July 2017

We have been speaking to HMRC about their recent ‘untaxed income’ nudge letter.

Technical
1 July 2017

The CIOT has challenged HMRC over its view on the application of the legislation to state and local taxes, saying that the draft guidance does not reflect the legislation, existing case law or the overarching policy behind the hybrid mismatch rules. HMRC’s view is also inconsistent with existing legislation and practice on double tax relief and the UK’s various treaty obligations.

Technial
1 July 2017

In March 2017 the government published a consultation document which considers proposals to bring non-resident companies within the charge to corporation tax in respect of income arising from UK real property and also gains which are currently taxed as non-resident CGT gains (NRCGT gains). The CIOT commented that we would prefer to see a strategic review of property taxation and that further work should be done on the Exchequer and economic impact of the proposals before any decision is taken.

Technical

Following consultation, the draft provisions introducing the cash basis for the calculation of the taxable profits of property businesses were included in Finance (No. 2) Bill 2017 at Clause 19 and Schedule 5. These provisions were dropped from the pre-election Finance Act 2017. At the time of writing we do not know whether (and from what date) the provisions may be re-introduced. However, as the proposed statutory cash basis for property businesses owes its origin, at least in part, to Making Tax Digital, it is reasonable to assume that it will be re-introduced. Therefore we continue to raise issues with HMRC based on the draft provisions.