In the case Putney Power Ltd v Revenue and Customs Commissioners, the core issue revolved around whether the company had commenced a "qualifying trade" for the purposes of the Enterprise Investment Scheme (EIS) under section 189 of the Income Tax Act 2007. The concept of "trade" in this context is critical because EIS relief is […]
In the recent case of Kevin McCabe v HMRC ([2024] UKUT 00280 (TCC)), the Upper Tribunal examined whether Mr. McCabe had ceased to be a UK resident during the tax years 2006/7 and 2007/8. The case involved complex issues of tax residency under both common law and the UK/Belgium Double Tax Convention (DTC), ultimately concluding […]
HMRC has recently launched a new wave of "nudge" letters aimed at individuals listed as Persons with Significant Control (PSCs) of companies. These letters are part of an effort to ensure that PSCs are meeting their tax obligations, with a particular focus on two groups: The clear implication from HMRC’s briefing suggests that their view […]
In Revenue and Customs Commissioners v Professional Game Match Officials Ltd (2024), the Supreme Court was called to determine the employment status of football referees engaged by Professional Game Match Officials Ltd (PGMOL). The key issue was whether these referees should be considered employees for tax purposes, which would obligate PGMOL to deduct income tax […]
A new policy paper was recently published by HMRC with more details around the new non-dom tax rules effective from 6 April 2025. Below is an overview of the key points: End of Remittance Basis The government confirmed that the 2024/25 tax year will be the last year for which the remittance basis can be […]
