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Practical Points

Every month, the Tax Faculty publishes short, practical pieces of guidance to help agents and practitioners in their day-to-day work.

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Business tax

This month covers employment taxes; international taxes; and VAT.
Employment taxes: Company liable for employers’ NIC
  • Mar 2025
HMRC has found that a company that subcontracted offshore duties remained liable to pay employers’ national insurance contributions (NIC) for the offshore workers, despite not being their official employer. The host...
International taxes: Appeal dismissed on the treatment of oil payments under UK-Canada treaty
  • Mar 2025
The Supreme Court has dismissed HMRC’s appeal in the tax treaty case of Royal Bank of Canada (RBC). The case concerned whether the UK had the right to tax contractual...
VAT: Application of extra-statutory concession
  • Mar 2025
Chelsea Cloisters Management Limited (CCML) is a management company for Chelsea Cloisters, a property of 656 apartments in London. The freehold owner is Realreed Limited, and the apartments are subject to long leases...
VAT: Whether café was a bar
  • Mar 2025
Anglia Ruskin Students’ Union (the Union) ran a bar or café called 92 at Anglia Ruskin University. The High Court has refused the Union’s application for judicial review of HMRC’s decision that 92 was a ‘bar’ and therefore did not qualify...
VAT: Whether exempt supply of land
  • Mar 2025
Sarabande is a charity that provides emerging artists with studio and exhibition space and other support. Sarabande claimed input tax on the acquisition and refurbishment of a property, which HMRC disallowed, on the basis that...
VAT: Inclusion of VAT invoices at hearing
  • Mar 2025
HMRC issued assessments to FS Commercial Limited on the basis that there was insufficient evidence to support input tax claimed. FS Commercial appealed against the assessments to the First-tier Tribunal (FTT), and in the...
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Personal tax

This month covers income tax.
Income tax: Court of Appeal grants taxpayer’s appeal on exceptional circumstances
  • Mar 2025
The Court of Appeal (CA) has found that a taxpayer was non-UK resident, as six excess UK days were due to exceptional circumstances. Her moral obligation to care...
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More in personal tax

Tax compliance and investigations

There are no updates this month.
Appeals, disputes and investigations: Discovery assessment on undeclared income held offshore
  • Feb 2025
The First-tier Tribunal (FTT) has upheld assessments on a taxpayer who moved undeclared income offshore, finding that HMRC had validly raised the assessments and penalties...
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Tax administration

There are no updates this month.
Agents and HMRC: Checking marriage allowance claims using PAYE codes
  • Dec 2023
Agents are able to check whether a client has an enduring marriage allowance claim using the client’s PAYE code. PAYE codes ending in the suffix ‘N’ indicate that an election is in place to transfer part of the personal allowance to a...
Tax returns: Relying on HMRC guidance
  • Nov 2023
Some advisers may have noticed an increase in the number of changes to HMRC’s guidance – in particular changes to articles in Agent Update and Employer Bulletin...
Making tax digital: Manual MTD registration required for some new VAT registrations
  • Oct 2023
When registering for VAT through HMRC’s VAT registration service, businesses should be automatically signed up to making tax digital (MTD). However, in some exceptional cases, the MTD registration is not being processed...
Tax payments and repayments: HMRC guidance on reducing self assessment repayment delays
  • Oct 2023
Self assessment repayments can be delayed at three different stages: 1. A delay to the processing of the return, form, or amendment that generates the repayment. 2. A repayment inhibitor is triggered. 3. The repayment is...
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More in tax administration

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