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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 international taxes; and VAT.
International taxes: Validity of pre-2009 dividend double tax relief claims following FII GLO, etc
  • Apr 2025
A number of judgments in recent years, such as the Supreme Court’s judgment in July 2021 in FII Group Litigation, clarified the principles in applying EU law to, and conforming...
VAT: Are Mega Marshmallows confectionery?
  • Apr 2025
The Court of Appeal (CA) has been asked to rule on whether a food product is ‘confectionery’ and therefore excluded from zero-rating. Innovative Bites Ltd contended that its product, Mega Marshmallows, was intended to be...
VAT: Broking services supplied to a Gibraltar insurer
  • Apr 2025
Hastings Insurance Services Limited supplied insurance broking services to Advantage Insurance Company Limited, a Gibraltar (non-EU) provider of insurance to UK policyholders. Although under EU and UK law, insurance transactions...
VAT: Valuation of intra-group charges
  • Apr 2025
Högkullen AB was the parent company of a Swedish group involved in real estate management. Högkullen’s subsidiaries were partially VAT exempt, and unable to fully recover input tax. Högkullen supplied services to its subsidiaries...
VAT: Application to strike out appeal on post-Brexit application of EU law
  • Apr 2025
The First-tier Tribunal (FTT) has refused to strike out an appeal concerning the post-Brexit application of EU VAT law. In January 2023, Mr Poulton submitted a VAT refund claim under the DIY housebuilders scheme...
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Personal tax

This month covers inheritance tax; and residence and domicile.
Inheritance tax: Taxpayer wins appeal on home loan scheme
  • Apr 2025
The Upper Tribunal (UT) found that a promissory note given by the deceased could be deducted from the value of the estate. This meant that the scheme under which she had remained in her home but it had technically been...
Residence and domicile: Some income from protected foreign settlement found to be taxable in the UK
  • Apr 2025
In the first case on this point to come to a hearing, the First-tier Tribunal (FTT) has found that offshore income gains (OIGs) and accrued income profits (AIPs) were taxable on...
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More in personal tax

Tax compliance and investigations

This month covers avoidance.
Avoidance: Dry tax charge upheld
  • Apr 2025
A taxpayer has failed in his argument that the Ramsay doctrine should be applied to arrangements into which he had entered. Although the whole scheme was ineffective, an element still gave rise to taxable income and thus a tax charge...
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More in tax compliance and investigation

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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