Matthew Harrison and Nicholas Donnithorne (Babbé) examine two decisions which, in their view, reflect poorly on HMRC.
Two recent decisions of the First-tier Tribunal (FTT) suggest that HMRC may be struggling to get to grips with certain basic provisions relating to the taxation of registered pension schemes. Or perhaps they indicate that HMRC is increasingly willing to litigate in relation to matters that appear hopeless to many practitioners. Either way those advising in this area should be aware of the latest thinking emanating from HMRC’s Pension Scheme Services.
Sippchoice v HMRC
Sippchoice Ltd v HMRC [2018] UKFTT 122 involved the availability of income tax relief in respect of in specie contributions to registered pension schemes. It has generated a significant amount of interest because HMRC saw fit to depart from its published guidance; a move which would have unfairly affected very many taxpayers had it been successful.
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Matthew Harrison and Nicholas Donnithorne (Babbé) examine two decisions which, in their view, reflect poorly on HMRC.
Two recent decisions of the First-tier Tribunal (FTT) suggest that HMRC may be struggling to get to grips with certain basic provisions relating to the taxation of registered pension schemes. Or perhaps they indicate that HMRC is increasingly willing to litigate in relation to matters that appear hopeless to many practitioners. Either way those advising in this area should be aware of the latest thinking emanating from HMRC’s Pension Scheme Services.
Sippchoice v HMRC
Sippchoice Ltd v HMRC [2018] UKFTT 122 involved the availability of income tax relief in respect of in specie contributions to registered pension schemes. It has generated a significant amount of interest because HMRC saw fit to depart from its published guidance; a move which would have unfairly affected very many taxpayers had it been successful.
...
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