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Since 1927 the leading authority on tax law, practice and administration

Mark Morton

Mark Morton is head of tax at Mercia Group Ltd, one of the UK’s largest providers of training and support services to the

accountancy profession. He can be contacted on tel: 0116 258 1200 or email: mark.morton@mercia-group.co.uk.

 

ARTICLES
MARK MORTON examines proposed revisions in the tax treatment of employer-supported childcare
MARK MORTON explains the calculations for the ‘anti-forestalling’ pensions charge in 2009/10 and 2010/11
MARK MORTON discusses HMRC’s right to demand access to a taxpayer’s private bank account
MARK MORTON and ANDREW BURGESS plumb the depths of the pensions anti-forestalling legislation
Is the new powers regime reasonable? MARK MORTON suggests that improvements could be made

Inland Revenue pay-as-you-earn auditors sometimes raise issues that can be sorted out without incurring further tax and National Insurance, explains MARK MORTON.

I RECENTLY BECAME involved with a company which had received its initial pay-as-you-earn audit visit. The letter sent out after this visit identified certain areas of risk. To be fair to the Inland Revenue official concerned, he remained friendly and approachable throughout the process, but his approach left me wondering how many other businesses around the country suffer in similar fashion.

MARK MORTON warns readers of the questionable tactics being used by the Revenue in close company full enquiries.

THE FOLLOWING IS the text of a letter issued by the Inland Revenue on 25 October 2001. In my experience, this letter is representative of the approach taken by the Inland Revenue in many corporate enquiry cases. What concerns the writer is that the majority of the requests in this letter are not appropriate.

HMRC's views on entrepreneurs' relief do not always coincide with those in the legislation, observes MARK MORTON
MARK MORTON writes an epitaph for the non-corporate distribution régime.
Is the Revenue taking more interest in whether or not companies are associated? MARK MORTON reports.

MARK MORTON illustrates an anomalous aspect of taper relief in a company winding-up and queries whether a concessionary practice exists.

SINCE TAPER RELIEF was implemented in April 1998, one common problem area has specifically centred on the liquidation of companies. The following example demonstrates the difficulty that arises.

Example

Benson Hotels Ltd has gone into liquidation following a trade and asset sale on the retirement of Benson, the company's controlling shareholder and managing director.

MARK MORTON looks at the latest changes to the IR35 provisions.
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