Field Court Tax Chambers

A gentle nudge
If there is one letter not to be ignored from HMRC, it is a nudge letter.  In this informative article (found on FCTC website here), Katherine Bullock sets out the practical aspects on the nature of such correspondence, what weight it holds, and critically how to deal with it.  This is a very practically useful article for both taxpayers and practitioners who find themselves in receipt of such a letter (or their clients in receipt of the same).  It deals with the Common Reporting Standard, and the prevalence of such letters, along with the careful and considered approach that should be taken when dealing with and responding to such missives.
A lucky break 
Earlier this year, the FTT handed down its decision in the case of Jasper Conran.  This was a factually complicated case, and in this article (on FCTC website here) Katherine Bullock carefully distils the essential principles as to how and why this is truly a case which amount to ‘the stuff of legends’. The article helpfully sets out the rationale behind why the FTT found that the market value of assets transferred from a limited liability partnership to a company on incorporation of a business was £1 (and not £8.25 million), thus resulting in the majority partner not realising a capital gain.  In exploring the FTT’s decision further, this article also sets out the basis for why the FTT also held that the consideration paid could not be treated as a distribution and that the buyer was not entitled to intangibles relief.

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