When it comes to R&D Tax Relief, software development is one area which has historically been challenging for both companies and advisers. Identifying whether a project qualified for relief could be difficult. Whilst it is easy sometimes to overlook “the other side of the fence”, these types of claims also 
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Crypto asset tax : The New HMRC Guidance Update… In December 2018, HMRC released their long-awaited policy paper on the appropriate tax treatment of cryptoassets. This being HMRC’s second paper on this, the first being published in 2014. The paper goes some way in undertaking the difficult task of marrying 
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January not only marks the start of the New Year but, for many people, a fresh start – a chance to make changes to their private and professional lives. However, for millions of people across the UK, it’s a time of stress as they make an annual attempt to finalise 
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What was NC26? NC26 (New Clause 26) was a cross party amendment to the Finance Bill proposed by the Liberal Democrat MP, Sir Edward Davey MP. In short, it asked for a review of the Government’s highly controversial, and deeply pernicious, April 2019 Loan Charge (“loan charge”).  The amendment passed 
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Tax Disputes with HMRC In this article we take a look at how to progress matters when discussions with the inspector appear to have broken down or reached an impasse. Where agreement just cannot be reached between the taxpayer and HMRC the final outcome is the Tax Tribunal. However, the 
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IHT and DOTAS HMRC recently introduced a new “hallmark” to the Disclosure of Tax Avoidance Schemes (DoTAS) regime with a view to closing the inheritance tax avoidance gap. The scope of the new hallmark is very wide, and consequently any inheritance tax planning should be carefully considered in light of 
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Judicial Review and tax Introduction – Judicial review and tax The 2019 Loan Charge Action Group has launched a judicial review against HMRC in relation to the 2019 Loan Charge. In recent years, the courts have seen a sharp increase in judicial review against HMRC. In light of this, I 
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McLaren Racing Ltd v HMRC… The Tax Position on CTA 2009 s54; Fines, Penalties, Expenses & Business Profits Tax relief (or not) for fines Legislation (CTA 2009 s54) states that a company can deduct expenses that are wholly and exclusively for the purpose of the trade against their business profits. 
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HMRC vs D Higgins; Off Plan Purchases & Principle Private Residence Relief (PRR) Exemption… The recent decision in the case of HMRC v Desmond Higgins [2018] UKUT 280 (TCC) confirms that Private Residence Relief (PRR) in relation to gains made on the sale of a house, originally purchased off-plan, does 
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Badges of trade: is there are trading activity? Introduction – badges of trade Do not confuse the ‘badges of trade’ with the ‘badgers of trade’. Whilst the latter is an organisation of mercantile woodland creatures, the former is a set of key indicators that are used to determine whether a 
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