DR Loan Charge – I’m an employer what do I do?

We reported recently that the Government had rejected calls to abandon the DR Loan Charge. There have been further calls for a delay to the loan charge since this but given the comprehensive rejection by the Government to similar suggestions … Continue reading

No deal Brexit – changes for UK employers sending workers to the EU, EEA or Switzerland

What is the issue? In HMRC’s latest Employer Bulletin, they issued guidance to employers on the social security contribution position for their UK employees who currently work in the EU, EEA and Switzerland in the event of a “no deal” … Continue reading

Are you ready for the 2018/19 expenses and benefits reporting season?

Our clients tell us that it is increasingly challenging to manage their employment tax risks and reporting obligations. This year promises to test even the best prepared employers further, given the unprecedented scale and rate of change to consider. Combined … Continue reading

VAT group representative member entitled to a group VAT reclaim, not the former VAT group member incurring the VAT

The significant sums claimed as a result of incorrect levying of VAT in the UK, such as in the case of car dealership trade and the bingo business, has led to a number of questions concerning who is entitled to … Continue reading

Can UK nil/gain nil loss taxation of intragroup transfers (normally only available for asset transfers within the UK), apply to cross border transfers?

A recent First tier Tribunal (FTT) decision in the case of Gallaher Limited has decided that TCGA s171 should apply to a transfer of shares from a UK group company to a Dutch group company – without any requirement for … Continue reading

Extended period for UK VAT reclaims by US businesses for 2017-18

HMRC has indicated that those US businesses prevented from making 13th Directive VAT reclaims for UK VAT for the 2017-18 period (the year to 30 June 2018) due to the inability to get a proper certificate of residence, may still … Continue reading

Consultation on preventing abuse of the SME R&D tax relief payable credit

HMRC has issued a consultation on preventing abuse of SME R&D tax relief that seeks to limit the abuse of the payable credit available to loss making companies.  The method of restriction will be to limit claims for the payable … Continue reading


Over the last month or so we have received many queries regarding the Disguised Remuneration Loan Charge and the options available in particular to avoid the Loan Charge. As the deadline for when the Loan Charge applies edges ever closer, … Continue reading

Government rejects all calls to abandon the DR Loan Charge

The Treasury has finally published its response as required by the Section 95 Finance Act 2019 (FA2019). Section 95 FA 2019 was an amendment to FA 2019 which required the Chancellor to review the Disguised Remuneration Loan Charge (“Loan Charge”). … Continue reading

IR35 – FTT upholds Lorraine Kelly’s appeal against HMRC decision

In the case of Albatel Limited, The First tier Tribunal (FTT) has held that a contract to provide Lorraine Kelly’s services to ITV for the ‘Daytime’ and ‘Lorraine’ programmes, was not a contract of service (subject to the IR35 intermediaries … Continue reading