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England and Wales decisions
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The tribunal refused Mr Paul Bryan’s application to direct HMRC to issue closure notices for open income tax enquiries, finding HMRC still had reasonable grounds to continue.
The First-tier Tribunal dismissed Mr Hakeem’s appeal against failure-to-notify income tax penalties, finding no reasonable excuse in hardship or reliance on a friend’s advice.
The tribunal held the partnerships were trading, but only the equity-funded part of each film advance qualified for relief; the debt-funded part did not.
The Tribunal allowed Mr Krason’s appeal against £224,750 in tax penalties, finding he did not act deliberately, conceal inaccuracies, or behave carelessly.
The tribunal upheld most income tax and VAT assessments against John Smith, finding he continued the accountancy business after its 2003 sale and acted deliberately.
The sums received by the shareholders (except for the Fourth Shares) were taxable as employment income under Chapter 3D of Part 7 ITEPA 2003 because the shares were employment-related securities acquired by reason of employment, and the consideration exceeded the market value, which was determined on a pro rata basis of the total consideration paid by the purchaser. The appellant was careless in failing to account for income tax and NICs on the excess, and the HMRC determination was validly made within the six-year time limit due to such carelessness. The appeal was allowed only in respect of…
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The tribunal found that a valid enquiry notice was given by HMRC's letter of 22 January 2021 to Grant Thornton, who were authorised agents for Mr Lester, and a closure notice was subsequently issued. Mr Lester validly made carry back claims for losses under s 72 ITA within the extended time limit provided by s 43(2) and s 43C(2) TMA, and any necessary amendment to prior carry forward claims was impliedly effected by the claims letter. The tribunal had jurisdiction to hear the appeal and the claims were validly made.
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The tribunal allowed Michael Parker’s appeal, holding that three transit days and one day of disruption were excluded under the Statutory Residence Test, leaving 89 UK days.
The Tribunal held that PGMOL’s match engagements with National Group referees were contracts for services, not employment, so the PAYE and NIC appeals succeeded.
The First-tier Tribunal allowed an appeal against Schedule 55 late-filing penalties after finding no notices to file had been served and the returns were voluntary.
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