Weekly case highlights ― 23 September 2024

Produced by a Tolley Owner-Managed Businesses expert

Owner-Managed Businesses

Guidance

These are our brief notes and thoughts on cases published in the last week or so which caught our eye and are likely to be of particular interest to tax practitioners. Full case reports and commentary on most of these cases will be included within our normal reference sources in the coming weeks.

Income tax

Haigh v HMRC

A brief note on this appeal against a refusal by HMRC to accept a late application for fixed protection under the 2012 pension regime.

The application was made over ten years late. The tribunal noted that there was no provision in the 2012 regulations for a reasonable excuse defence in a late appeal case and agreed with HMRC that the late application could not be admitted. The comments at para 82 rejecting the taxpayer’s argument that HMRC should have notified him of the need to consider making an election are worth reading.

Employment tax

HMRC v Professional Game Match Officials Ltd

This is an important Supreme Court case on employment status. It concerns part-time

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