April_Quarterly_Workshop

Report
Tax! Fundamental Roles
& Worked Examples
Chris Wilkins
Wilkins Southworth
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Overview
1.
2.
3.
4.
5.
6.
7.
Abolition of The Renewals Basis
VAT 708
Sideways Loss Relief
Real Time Information (RTI)
National Employment Savings Trust (NEST)
High Income Child Benefit Charge
Tax Cases
- Emoluments, dividends or both?
-
Overdraft or loan interest?
Relief For Interest on Loans To A Close Company
Payments Under Guarantees
8. Dutch Sandwich
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The Renewals Basis
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The Renewals Basis
• HMRC announced that the concessionary renewals
allowance for the replacement of plant other than trade
tools will be withdrawn with effect from April 2013.
• S.68 ITTOIA 2005 gives a specific deduction for the cost
of replacing tools that are used for the purposes of a
trade.
• By concession, before the introduction of capital
allowances for plant and machinery, this treatment
(known as the ‘renewals basis’) was extended to
expenditure on other plant and machinery, on the
following main conditions: BE MORE - DO MORE - HAVE MORE - GIVE MORE
The Renewals Basis
- No capital allowances or other deductions are available
on the cost of the original asset, which must be disposed
of before a renewals allowance can be claimed (S.35 CAA
2001).
- No relief is available for the cost of any improvement of
the replacement asset.
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Wear & Tear Allowance?
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The Renewals Basis
What happens now?
a) Where a residential property is let furnished, the 10%
‘wear and tear’ allowance in respect of the depreciation
of plant and fixtures can be claimed.
- An allowance for wear and tear may be made, where
capital allowances are not due, by deducting 10% of the
net rent received.
- Where the 10% deduction is allowed, no further
deduction is given for the cost of renewing furniture or
furnishings, including suites, beds, carpets, curtains,
linen, crockery or cutlery.
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The Renewals Basis
- Nor is a further deduction allowed for chattels of a type, which in
unfurnished accommodation, a tenant would normally provide for
himself (for example cookers, washing machines, dishwashers).
- However, in addition to the 10% wear and tear allowance, the
landlord can also claim the cost of renewing fixtures which are an
integral part of the buildings and which are revenue repairs to the
fabric. These are fixtures which would not normally be removed
by either tenant or owner if the property were vacated or sold (for
example, baths, washbasins, toilets and central heating boilers).
Expenditure on renewing such items may be treated as
expenditure on repairs even though the 10% allowance has been
claimed
Extra Statutory Concession ESC B47
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The Renewals Basis
b) Where a residential property is let unfurnished
• A furnished property is one that is capable of normal
occupation without the tenant having to provide their
own beds, chairs, tables, sofas and other furnishings,
cookers etc. The provision of nominal furnishings will
not meet this requirement. If the accommodation is not
furnished, or only partly furnished, the 10% wear and
tear allowance is not due.
• HMRC Property Income Manual PIM 3200
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Detailed Profit & Loss Account
Example
ABC LIMITED – YEAR ENDED 31ST AUGUST 2012
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Detailed Profit & Loss Account
Example
ABC LIMITED – YEAR ENDED 31ST AUGUST 2012
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Wear & Tear Allowance
ABC LIMITED – YEAR ENDED 31ST AUGUST 2012
In accordance with ESCB47 an allowance for wear and tear
can be made, where capital allowances are not due, by
deducting 10% of the net rent received. For this purpose
the net rent is calculated by deducting charges and services
that would normally be borne by a tenant but are instead,
borne by the landlord. If we assume for the purposes of
this example that the accounts figures for the year ended
31 August 2013 will be the same as 31 August 2012. The
wear and tear allowance we can claim is as follows:BE MORE - DO MORE - HAVE MORE - GIVE MORE
Wear & Tear Allowance
ABC LIMITED – YEAR ENDED 31ST AUGUST 2012
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VAT 708
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VAT 708
• In order to qualify for the reduced rate of VAT of just 5%,
a residential conversion must result in a multiple
occupancy dwelling, such as where a self-contained
dwelling is converted into a number of non-self
contained ones.
• The reduced rate of VAT is also applicable where a
multiple occupancy dwelling that has been empty for at
least two years, is renovated or altered (prior to 1
January 2008, the dwelling had to have been empty for
three years).
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VAT 708
What ‘multiple occupancy dwelling’ means:
• A ‘multiple occupancy dwelling’ is defined in Value
Added Tax Act 1994, Schedule 7A, Group 6, paragraph 4
of the notes.
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VAT 708
What ‘designed for occupation by persons not forming a
single household’ means:
• A dwelling designed for ‘persons not forming a single
household’ is a building (or part of a building) where the
living space is to varying degrees shared by persons not
forming a single household. A typical example would be
a block of bedsits, where the occupant households share
the amenities – for example, the bathroom or the
kitchen.
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VAT 708
• Excluded from the meaning of ‘dwellings designed for
persons not forming a single household’ are buildings
that are used to any extent for a relevant residential
purpose. The clause, which was introduced with effect
from 1 June 2000, clarifies that the terms refer to
different and distinct types of property.
• A dwelling is ‘designed’ as a ‘multiple occupancy
dwelling’ if it is built for that purpose (and not
subsequently altered to something different – for
example, offices), or has been altered to that purpose
from some other use – for example, a barn.
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VAT 708
Conditions:
• VCONST14120, VCONST14130 and VCONST14140 apply
in the same way as they do for buildings ‘designed as a
dwelling or number of dwellings’.
• A dwelling consists of self-contained living
accommodation when the basic elements of living
(sleeping, washing, preparation of food, and so on) are
located together within a defined area and are not
shared by more than one household or tenant.
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VAT 708
• A ‘bed-sit’ wouldn't qualify as self-contained living
accommodation because some of the elements of living
are shared with other ‘bed-sits’, whereas a studio flat
where all the elements of living are contained within the
flat would be self-contained living accommodation.
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VAT 708
In Agudas Israel Housing Association Ltd (VTD 18798), the
Tribunal held that a bedsitting room with en suite shower
room (one of eight), constructed as an enlargement to an
existing care home, was self-contained living
accommodation. In this case, the VAT tribunal said:
‘in the 21st Century premises with their own front door,
ensuite bathing facilities and the ability to cook with a
microwave and kettle are self contained living
accommodation’.
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VAT 708
In Oldrings Development Kingsclere Limited (VTD 17769),
the Tribunal held that a new studio room did consist of
self-contained living accommodation. It contained certain
facilities such as a WC with hand basin in a separate room,
a kitchen sink and sufficient electrical points for cooking
appliances, its own separate central heating and hot water
system but it didn't have a shower unit or bath installed.
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VAT 708
In SA Whiteley (VTD 11292), the Tribunal held that the use
of the singular of ‘a building’ in Note 2 meant that the
basic elements of living had to be contained within one
building and not spread around several buildings.
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Sideways Loss Relief
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Sideways Loss Relief
• Whereas previously there has been no limit on the
amount of losses that can be offset against general
income, a cap will now be set at £50,000 or 25% of your
adjusted total income, whichever is the greater.
• The cap will not apply to ‘limited reliefs’ such as pension
contributions, Seed Enterprise Investment Schemes
(SEIS), Enterprise Investment Schemes (EIS) and Venture
Capital Trusts (VCT).
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Sideways Loss Relief
• The reliefs which will potentially be capped within the
new regime are:
– Share loss relief
– Trade loss relief against income
– Early trade loss relief
– Post cessation trade relief
– Property loss relief against income eg. capital
allowances
– Post cessation property relief
– Employment loss relief
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Sideways Loss Relief - Example
• Mr Dawson has trade losses in 2014/15 of £200,000 and
2013/14 profits from the same trade of £70,000.
• He has other income in each tax year of £120,000.
• Mr Dawson’s relief against general income is restricted
to £50,000 for both the 2013/14 and 2014/15 tax years.
• He then elects to set £50,000 (capped) against his
2014/15 general income and to carry back £70,000
against 2013/14 profits from the same trade.
• He also claims to carry back £50,000 against his general
income in 2013/14.
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Sideways Loss Relief - Example
Mr Dawson’s taxable income for the respective tax years is as
follows:-
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Real Time Information
(RTI)
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Real Time Information (RTI)
• HMRC are introducing major changes in the way PAYE
information is reported to them.
• The Real Time Information procedures mark the biggest
change in the Payroll and PAYE system since the
commencement of PAYE nearly 70 years ago.
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Real Time Information (RTI)
• Under RTI, employers and pension providers are
required to provide detailed information to HMRC in
respect of more or less all wages/salaries on or before
each payment date, instead of after the end of the tax
year.
• This system of Real Time reporting is designed to ensure
that HMRC has both up to date and accurate details of
employment income and tax deductions for all PAYE
taxpayers, thereby reducing the number of end of tax
year reconciliations with resultant underpayments and
repayments.
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Real Time Information (RTI)
• This will provide the Department of Work & Pensions
with up to date information regarding claimants’
employment income, enabling calculations of Universal
Tax Credit payments to be made on a monthly basis
without the need for further information submissions by
individual claimants.
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Real Time Information (RTI)
• Some aspects that will remain the same, in particular
employers will still use codes to determine the amount
of tax to be deducted from employees, P60s, P45s and
P11Ds will continue to be used and PAYE/NI deductions
will still be due to HMRC by the 19th/22nd (depending
upon the payment method used) of the following
month.
• However with RTI HMRC will be in a much better
position to pursue unpaid deductions and impose
penalties in respect of late payments.
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Real Time Information (RTI)
• RTI will be compulsory for all entities operating a PAYE
system and employers should start preparing for its
implementation now in order to ensure they are ready
for RTI commencement (for most employers 6 April
2013) and help to avoid any penalties imposed as a
result of failing to comply with the new system.
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Real Time Information (RTI)
• Separate pieces of information reported to HMRC are
known as ‘data items’.
– Under RTI there will be major changes to the data items
required to be reported.
– In total there are over 150 potential individual data items
that could be required ranging from basic items such as
name, date of birth, gross pay, etc through to more
unusual items, notably passport numbers for certain
workers, banding of contracted hours for all employees,
tax free payments and payments made to casual workers.
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Real Time Information (RTI)
• As part of the process for an employer joining RTI, HMRC
will align the records of employees held on their
National Insurance and PAYE system with the records
held by each employer through an Employer Alignment
Process.
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Real Time Information (RTI)
• Employer alignment is an important process that all
employers will need to undergo as part of the joining
process for RTI.
– Alignment will ensure that the employer and HMRC both
hold consistent information in respect of employees in
every PAYE scheme before reporting using RTI begins.
– It is therefore important that correct and complete details
are held in respect of full employee names, dates of birth,
addresses, NI numbers and gender.
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Real Time Information (RTI)
– Where, for instance, NI numbers are not known or not
issued, e.g. to those under 16, the data must be left blank
and temporary, dummy, default information must not be
used.
– It is recommended that employers gather together all the
relevant information and then ask each employee to
check their own respective data. Where there is incorrect
data held by HMRC then the employee will have to
contact HMRC to have the error corrected.
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Real Time Information (RTI)
• An alignment submission can only be made once and
amendments cannot be made once submitted.
• This process is designed to make it easier for employers
to submit information to HMRC once RTI is fully
implemented.
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Real Time Information (RTI)
Commencement Date
• Most employers and Pension providers will begin to use
the RTI service in April 2013 with almost all employers
using the new system by October 2013.
• Once the new system commences a return of all
employee payments must be made on or before each
payment date where any employee is paid more than
the Lower Earnings Limit (and this return must include
payments made to employees both above and below the
Lower Earnings Limit).
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National Employment
Savings Trust (NEST)
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National Employment Savings
Trust (NEST)
• NEST is effectively a compulsory pension scheme into
which all employees are to be enrolled with a view to
providing a retirement pension in due course in addition
to the State pension.
• Employers must automatically enrol their employees
(between the ages of 22 and the state retirement age
who earn more than annual personal tax allowance) into
NEST unless they already run a pension scheme with
comparable benefits.
• For those employers with less than 50 employees the
commencement date will be between 1 June 2015 and 1
April 2017.
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National Employment Savings
Trust (NEST)
• All qualifying employees must be automatically enrolled
into NEST unless they specifically opt out or there is a
comparable pension scheme arrangement already in
place.
• Initially employers will have to contribute at least 1% (of
salary) to the scheme but this will increase to 2% in
October 2017 and 3% in October 2018.
• Employee contributions will be required at similar rates
(employees will receive 20% tax relief at source on their
contributions).
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High Income
Child Benefit Charge
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High Income
Child Benefit Charge
Commenced on 7 January 2013:
• Affects a couple living together who claim it where one
partner earns £50k or more; and
• An individual recipient with no partner, whose adjusted
net income exceeds £50k.
• If they earn more than £60K there is no tax benefit in
claiming it.
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High Income
Child Benefit Charge
• However, claims should still be made for any new
children, even though Child Benefit payments will not be
received for them, as each week of entitlement to Child
Benefit could qualify for National Insurance credits,
which can help to protect future entitlement to State
Pension.
• Credits apply where there is entitlement to Child Benefit
for children under the age of 12 and this continues until
the youngest child is 12.
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High Income
Child Benefit Charge
What can I do to influence this: • Typical scenario is husband works and earns say £52k,
wife has two children at home looks after HMOs and
gets a salary from HMO company of say £7.5k. Neither
of them have any other income. Then ensure that
husband has no dividends from HMO co, it all goes to
wife. Do this by different classes of shares.
• If husband has other income then gift
shares/investments to wife. Not so easy if they are not
married as it may trigger a CGT charge
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Tax Cases
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Emolument or dividend or both?
• Whether payments made to employee shareholders
should be viewed as distributions or emoluments for tax
and NIC purposes.
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Emolument or dividend or both?
The facts:
• For 2000/01 to 2002/03, a company, P, entered into complex
arrangements under which it paid certain employees bonuses in
the form of dividends, which were financed from a capital
contribution to P from Employee Benefit Funds, in turn derived
from P.
• HMRC imposed determinations and P and one of its employees
appealed, contending that the income was chargeable to income
tax under Schedule F and could not also be subjected to PAYE or
charged to national insurance contributions.
• Both the First-tier and Upper Tribunals viewed the payments as
chargeable to income tax under Schedule F but subject to NIC as
employment earnings.
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Emolument or dividend or both?
• HMRC appealed against the decision of the Upper
Tribunal, contending that the dividends were in realty
bonuses and liable to be taxed under Schedule E,
Schedule F and Section 20(2) did not apply.
• P contended, as an additional ground for upholding the
decision, that the dividend income was not from
employment.
• P also appealed against the decision that the payments
received in the form of dividends were ‘earnings’ for the
purposes of NIC on the same basis: that the income was
not from employment.
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Emolument or dividend or both?
The decision (CA)
• It was necessary for the court not to be restricted to the
legal form of the source of the payment but to focus on
the character of the receipt in the hands of the recipient.
• Here, the intention was to motivate and encourage the
employees, and payment was represented to them as
payment of the bonus for that year.
• The tribunals had adopted that approach which enabled
them, within accepted limits, to look beyond the form of
distributions, mere machinery, by which the intention to
pay bonuses was fulfilled.
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Emolument or dividend or both?
• Once that conclusion had been reached, there was no
room whatever for any further consideration of a
different Schedule.
• If the payments were emoluments in the hands of PA’s
employees, they could not be dividends or distributions
in the hands of those employee’s, they could not be
dividends or distributions in the hands of those
employees.
• Any other conclusion offends the basic principle
expressed in Fry v Salisbury House Estate Ltd (1930) AC
432 that if income falls within one Schedule it cannot be
taxed under another.
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Emolument or dividend or both?
• The inserted steps which created the form of dividends
or distributions did not deprive the payments of their
character as emoluments, and had no fiscal effect.
• The Court of Appeal unanimously upheld the appeal of
HMRC in respect of taxation and dismissed that of P in
respect of NIC.
(HMRC v PA Holdings Ltd (and cross-appeal) CA 30.11.11)
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Nature of borrowing –
Overdraft or Loan?
The issue
• Whether a taxpayer was entitled to deduct the interest
of an overdraft extended for business purposes.
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Nature of borrowing –
Overdraft or Loan?
The facts
• The taxpayer, G, and his wife owned a rundown caravan
site in Yorkshire.
• They decided to develop the land for the rental and sale
of retirement and mobile homes.
• They formed a company for this and for future trading
activities.
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Nature of borrowing –
Overdraft or Loan?
• In June 2004, Lloyds TSB Bank offered Mr and Mrs G a
personal overdraft facility of £1,045,000.
• This included ‘any other account that may be opened as
a replacement or substitution for it’.
• The taxpayers said that they intended at some stage to
transfer the overdraft borrowings into the name of the
company, but for the time being the facility was provided
to them personally rather than to the company.
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Nature of borrowing –
Overdraft or Loan?
• G submitted self assessment tax returns on which he
included interest received from the company for the years
2003/04 to 2005/06 respectively.
• The company accounts showed that it paid interest of
£128,464 to G in respect of working capital loans provided to
the company.
• No tax was withheld from the interest payments,
nor had it accounted for any deduction.
• HMRC accordingly issued assessments under Sch 16 TA 1988
to the company in respect of its obligation to deduct and
account for income tax on the interest payments.
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Nature of borrowing –
Overdraft or Loan?
• G claimed that the £128,464 was a reimbursement by
the company of overdraft interest paid personally by
himself and his wife in respect of the working capital.
• HMRC decided the sum was interest and should have
been shown on his personal tax return and raised
assessments accordingly.
• G claimed relief under S.353(1) ICTA 1988 in respect of
the interest, claiming the overdraft account represented
a qualifying loan for business purposes.
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Nature of borrowing –
Overdraft or Loan?
The decisions (FTT)
• The First-tier Tribunal decided that the borrowing was an
overdraft and therefore ineligible for relief under
S.353(3).
• The future intentions with regard to the borrowing were
not relevant.
• While the tribunal had sympathy for G, its decision had
to be based on the facts and not on what they may or
may not have intended.
– G’s appeal was dismissed.
(W. Green v HMRC TC1502 11.10.11)
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Relief for interest on loan
to close company
The issue
• Whether an individual had a material interest in a close
company and, accordingly, whether he could claim
interest on a loan to that company.
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Relief for interest on loan
to close company
The facts
• N agreed to lend £100,000 to a company, V, of which he
was a director.
• He financed this loan by increasing the mortgage on his
house, and claimed relief under what is now S.392 ITA
2007 for the additional interest he had to pay.
• HMRC rejected the claim on the grounds that, although
N was a director of V, he did not own any shares in V and
thus did not have a material interest in V.
• N appealed.
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Relief for interest on loan
to close company
The decision
• The First-tier Tribunal allowed N’s appeal, finding that he
had a 50% interest in a company, P, which was associated
with V, whose controlling director was a major shareholder in
P and was P’s main creditor, entitling him to receive the
greater part of P’s net assets if it were to be wound up.
• Judge Geraint Jones held that the effect of what is now
S.394(4) ITA 2007 was that N should be treated as having a
material interest in V, as he was a significant loan creditor
and was therefore a ‘participator’ in V.
(A Nowosielski v HMRC TC01907 30.3.12)
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Payments Under Guarantees
(Peter Goldsmith v HMRC)
• The First-tier Tribunal recently ruled that payments to a
lender by a guarantor did not meet the conditions for tax
relief.
– Mr Goldsmith was a director of a property trading
company.
– The company took out a bank loan which he guaranteed.
– The rental payments on one of the flats never covered the
mortgage interest.
– Mr Goldsmith met the shortfall.
(a) Mr Goldsmith claimed tax relief on his payments.
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Payments Under Guarantees
(Peter Goldsmith v HMRC)
This was denied by HMRC because: i. HMRC’s Capital Gains Manual (CG66012) states that if
the lender is required to issue a formal demand, but no
demand is issued, this will not in itself preclude a claim
for relief.
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Payments Under Guarantees
(Peter Goldsmith v HMRC)
ii. However, if there is no requirement by the lender to
issue a demand, there should be no difficulty in
accepting that a payment was made under the
guarantee provided that all other conditions are met.
These are: – The loan has become irrecoverable.
– The guarantor has made a payment under the guarantee.
– The guarantor has not assigned the right to recover the
amount which has accrued to him in consequence of
making the payment.
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Payments Under Guarantees
(Peter Goldsmith v HMRC)
What To Do In Future
In all cases: a. Payments should only be made after the loan has
become irrecoverable.
b. If an asset belonging to the guarantor is to be sold at a
gain pursuant to the repayment of the loan, care should
be taken to ensure that the sale does not take place in
an earlier tax year to that in which the guarantee
payment is made.
c. Copies of documentation regarding the guarantee,
demands and payments should be kept.
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Dutch Sandwich
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Dutch Sandwich
Irish Company
Dutch
Company
Bermudan
Company
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Chris Wilkins FCCA, Managing Partner, Wilkins Southworth
E: [email protected]
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