Andrew Goldstone and Nicola Simmons review recent tax case law and other developments.
In West, an employee was made liable for PAYE/NICs instead of the employer. In Ackroyd, a BBC/personal service company arrangement was treated as one of employment for income tax purposes under IR35. HMRC continued its run of defeats for filing penalties in Jackson.
HMRC has issued further guidance on the deemed domicile rules for cleansing mixed funds, and it has also published new guidance on the IHT DOTAS rules. Consultations have been launched on extending entrepreneurs’ relief; countering avoidance by profit fragmentation; and the tax treatment of charities.
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