Tax Disputes & Resolutions quarterly round up: July – September 2024

Negotiating payment plans

We understand that it is not always possible to settle your tax bill on time. This may be because of a change in circumstances or an unexpected tax bill. If you do not inform HMRC, it will commence enforcement action, which can range from calls or visits to your address from HMRC’s Debt Management team, right up to bankruptcy action, in the worst case. Read more here

R&D – Disclosure facility

HMRC has also announced the development of a dedicated R&D disclosure facility and anticipates the Facility will go live by the end of June. Remember this may not be the most appropriate disclosure method based on individual circumstances. Please seek professional advice. Read more here.

HMRC’s continued use of nudge letters

One of the latest communications in HMRC’s nudge letter campaign targets those who HMRC believes has disposed of crypto assets without declaring the resultant chargeable gains or income in their tax filings. HMRC has previously sent nudge letters to remind individuals who held crypto assets, including cryptocurrency, of their obligation to report transactions, but the current communication goes a step further. Read more here.

Dual representation

New Football Association (FA) regulations for agents came into force in January 2024 and dual representation is a prominent feature. Dual representation has been an area of focus for HMRC for some time, and it published supplementary guidance on 13 May 2024, to assist with the reduction of filing errors. Read more here.

Pension pitfalls

With an ageing population, pensions are a key focus and often a political hot-potato. The Government faces a continual balancing act of wanting to encourage people to save for their retirement by providing tax incentives, while balancing the budget. The constant changes to the rules around pensions have resulted in a very complex regime, which unfortunately includes potential tax charges that can be inadvertently triggered. In the following article we focus on just one of these, caused by making contributions that exceed your Annual Allowance. Read more here.

Hybrid partnership tax schemes

Late last year we reported that HMRC was aware of a tax scheme being marketed at property businesses involving hybrid partnerships, such as Property 118 and Less Tax for Landlords, which “promised”, inter alia, reduced Capital Gains and Inheritance Taxes. HMRC is actively investigating these schemes and we have had a number of recent conversations with landlords who were not aware that their structures were regarded as failed schemes by HMRC. If you are under an HMRC investigation, or believe you may inadvertently entered into such a scheme, lease reach out to us for guidance. If you are under an HMRC investigation, or believe you may inadvertently entered into such a scheme, please contact Danielle Ford, Partner, Head of Tax Disputes and Resolutions.