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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 capital allowances; corporation tax; international taxes; and VAT.
Capital allowances: Supreme Court rules in HMRC’s favour on capital allowances in enterprise zones
  • Jan 2025
The Supreme Court ruled in HMRC’s favour that costs incurred more than 10 years after the cessation of the zone’s tax-favoured status do not qualify for enhanced allowances, even if part of an earlier contract...
Corporation tax: Loan to finance an intra-group acquisition had unallowable purpose
  • Jan 2025
The First-tier Tribunal (FTT) ruled in HMRC’s favour that a loan used to fund a share acquisition had an unallowable purpose of obtaining a tax deduction, and so interest deductions were denied. The FTT...
International taxes: Court of Appeal refuses judicial challenge to diverted profits tax notice
  • Jan 2025
The Court of Appeal has dismissed the taxpayers’ appeal in the diverted profits tax (DPT) judicial review case of Refinitiv Limited and others. The taxpayers were challenging the lawfulness of DPT notices for 2018...
VAT: CJEU decision on VAT on intra-group services
  • Jan 2025
In June 2016, Weatherford Atlas Gip, part of the Weatherford group of companies (the group) that specialised in oil services, acquired Foserco SA, a Romanian company, and another member of the group. Prior to its acquisition, Foserco had...
VAT: Upper Tribunal VAT decision on further education business activities
  • Jan 2025
Colchester Institute Corporation (the College) reclaimed VAT on its 2008 campus redevelopment, applying the Lennartz mechanism, which (at the time) allowed VAT recovery on costs relating to non-business activities...
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Personal tax

This month covers income tax; and property tax.
Income tax: Actor left with £1.8m tax bill
  • Jan 2025
The First-tier Tribunal (FTT) has found that an arrangement was ineffective where rights to film income was put into a company and some of the money received from this was treated as capital due to it being a disposal of the rights. This amount was taxable...
Property tax: Upper Tribunal dismisses appeal on SDLT group relief main purpose test
  • Jan 2025
The Upper Tribunal (UT) has dismissed an appeal by a taxpayer in the stamp duty land tax (SDLT) case of The Tower One St George Wharf Limited. The case relates to a series of transactions for the transfer of the freehold...
Property tax: Property residential for LBTT
  • Jan 2025
Revenue Scotland (RS) successfully argued that an historic property was residential. Although it had been used as offices for a time, it was purchased on the basis that that use would change and it was suitable for use as a dwelling...
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More in personal tax

Tax compliance and investigations

There are no updates this month.
Penalties: Reasonable excuse
  • Nov 2024
A new penalties regime has applied from 1 January 2023 to the late submission and late payment of VAT returns. Under this regime, a taxpayer may not be liable to a penalty if they...
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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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