Retail offer held to be partly standard rated rather than fully zero rated for VAT

The Upper Tribunal has held that Marks & Spencer’s ‘meal deal’ offer (three food items for £10 plus a free bottle of wine or non-alcoholic equivalent) was a packaged offer the consideration for which needed to be apportioned across all … Continue reading

HMRC’s business risk review process for large corporate taxpayers will change from 1 October 2019

HMRC has indicated it will be rolling out its new business risk review categorisation for large business from 1 October 2019. This follows consultation in December 2017 and the subsequent operation of a pilot by HMRC.  Currently there are only … Continue reading

The State of Status – The Finance Bill and Off-Payroll Working in the Private Sector

The Finance Bill was published on 11th July. It was eagerly anticipated, mainly due to an expected update on how the off- payroll working rules introduced to the public sector in April 2017 were to be extended to the private … Continue reading

Finance Bill 2019-20 measures effective from 11 July or earlier

Below are some notes on Finance Bill 2019/20 measures that took effect from 1 or 24 January 2019 or 11 July 2019. For a further discussion of the implication of these or any other Finance Bill 2019/20 measures, please get … Continue reading

FB 2019/20 – April 2020 introduction of the Digital Services Tax

FB 2019/20 – Digital Services Tax Draft legislation, explanatory notes and guidance have been released for the UK’s 2% digital services tax due to come into force from 1 April 2020.  The consultation on these draft documents will run until … Continue reading

FB 2019/20 – April 2020 introduction of the corporate capital loss restriction

Draft legislation has been issued to bring carried forward capital losses within the new corporate loss regime for the UK.  This means that in working out the amount of corporate profits against which brought forward losses can be offset, the … Continue reading

Unpaid office holder expenses- exemption to replace ESC in April 2020

The 2019-20 Finance Bill will turn the existing income tax Extra-Statutory Concession (ESC) for expense payments to voluntary office holders into a statutory exemption from 6 April 2020. A corresponding Class 1 National Insurance contributions disregard will apply from the … Continue reading

Concept of ‘final losses’ when considering the ability to offset cross border losses within an EU group

Two recent CJEU cases concerning the Swedish tax Authority’s application of ‘M&S cross border loss relief’ have discussed what is meant by ‘final losses’ in the context of claims for cross border loss relief. The UK provisions for cross border … Continue reading