Private residence relief

The Capital Gains Tax (CGT) relief on disposal of an individual’s only or main residence is very valuable and well known. Taxpayers are generally aware of the need to reside in the property, which is... Read more

HMRC: Time to Pay

Most tax professionals and many taxpayers will be familiar with the concept of ‘time to pay’ (TTP) arrangements with HM Revenue and Customs (HMRC). The basic position of HMRC is that tax is payable... Read more

HMRC Enquiries

Most tax agents involved with enquiry work will be familiar with the HMRC practice of 'spreading'. This generally occurs when there is an agreed addition to the taxpayer's income for the year of... Read more

Loan relationships – When is a loan not a loan?

The loan relationships provisions for companies have been around since 1996, and it is fair to say that the legislation overall is complex. However, it is not normally difficult to identify a loan... Read more

Private residence relief – Married couples ‘living together’ for CGT purposes

Married couples (and civil partners) benefit from favourable treatment for certain tax purposes. A common example is the ‘no gain, no loss’ capital gains tax (CGT) treatment for inter-spouse... Read more

Ownership and tax issues – HMRC guidance on constructive and resulting trusts

It is straightforward in most cases to establish an individual’s income entitlement for tax purposes. However, there are exceptions. HM Revenue andCustoms (HMRC) recently issued new guidance in its... Read more

Penalties and costs – The taxpayer fights back

Taxpayers have recently been successful in a number of appeals before the tax tribunal on the grounds of ‘reasonable excuse’, mainly in respect of late filing penalties. One such case is highlighted... Read more

HMRC Information notices

Taxpayers can be required to provide HM Revenue and Customs (HMRC) with certain information and/or documents, if HMRC issues a written notice to that effect (FA 2008, Sch 36, para 1; previously TMA... Read more

Assessments and appeals - What can taxpayers appeal against?

It is normally straightforward to tell when HM Revenue and Customs (HMRC) have raised an assessment in respect of a taxpayer. However, what constitutes an ‘assessment’? This is an important question... Read more

HMRC Enquiries

When a HMRC enquiry notice into a tax return arrives, it is perhaps natural to anticipate a long, drawn out process to completion. This is particularly the case with full (as opposed to aspect)... Read more

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