Genius News


Class 2 NICs are to be abolished from 2018, in a move calculated to give a tax cut of more than £130 for 3m self-employed workers

Currently about 3

4m people pay Class 2 NICs at a rate of £2

80 a week, which contributes to their state pension entitlement and other benefits

Sources - Financial Times, Daily Mail, The Sun, The Times, Budget 2016,

Osborne shuts personal service loophole A tax loophole used by public sector employees including BBC presenters and civil servants has been closed

George Osborne said public sector employees will no longer be able to use personal service companies to lower their bill

The Times, Budget 2016, Daily Mail, Independent

Amazon 'under investigation in Italy for alleged tax evasion' Amazon's business in Italy is under investigation for alleged tax evasion, Francois Nuyts, Amazon’s chief for Italy and Spain, has revealed

“Amazon pays all applicable taxes in every jurisdiction where we operate, including Italy, and we are cooperating fully with the Italian authorities,” said Mr Nuyts

Evening Standard

Interestingly, the Labour party has started saying it must reach out to self-employed, with their 'Red Shift' group believing the party is doomed to failure unless it adapts to the new world of working people

They have acknowledged that the world of work has dramatically altered with increasing number of people choosing to work flexibly, naming 'mum-preneurs' and Uber drivers as examples

We will be monitoring to see whether this 'Red Shift' movement gathers momentum and delivers Labour policies that will truly support the self-employed

Of course, most politicians wax lyrical about the value of the flexible workforce

And yet, despite political recognition, we are now faced with a barrage of initiatives that have the potential to significantly impact on the same hardworking individuals that Government claim to support

All of us involved in supporting freelancers and contractors are spending the summer unpicking the nuances of the onslaught, deciphering technicalities to establish the true impact of proposals on the workforce

Earlier today I felt defeated by it all, and started to wonder what the point is

I believe that Government does value the flexible workforce, at least the MPs I meet with certainly do

However, the reality is that there are many complexities within our sector and the mechanics of engaging the flexible workforce are not straight forward

It can be difficult enough for so-called 'experts' to grasp the finer points, let alone MPs and civil servants

So that leaves us to educate and help them understand

We all have a responsibility to use the raft of opportunities to point out unintended consequences, even if it seems like hard work and that we are repeating the usual messages

Otherwise, we risk endangering the very workforce which is so important to UK prosperity and our future

- Julia Kermode, CEO of the Freelancer & Contractor Services Association

The release of the growth figures by the Official for National Statistics is a bit like peeling an onion

UK number crunchers have three goes at estimating the quarterly performance of the economy and a little more is revealed each time

In October, the ONS released its flash estimate of GDP for the third quarter based on the output of sectors such as manufacturing, construction and services

This showed the economy had expanded by 0

7% between the second and third quarters

More data has rolled in over the past month

So we find out how much of the growth was due to consumer spending, how much was due to government spending, the contribution of investment, whether firms are building up or running down their stocks, and what is happening to trade

The message from the expenditure components of growth is that the rebalancing of the economy is still some way off

The domestic economy expanded by 0:9%, with trade knocking 0:2 points off the quarterly growth rate

Consumer spending rose by 0

8% in the third quarter, while government expenditure was up by 1:1%

Business investment fell by 0

7%

Ministers can point to the weakness of the Eurozone to explain away the poor export performance

So, yes, the economy is growing

And, yes, it is growing faster than that of Germany or France

But it is the same old economy, with the same old weaknesses

5% of the outstanding tax, plus the standard daily interest on the original debt, the FT reported

5% charge, says a HMRC letter reportedly left at the house

The debtor not honouring a Time to Pay agreement was said to have led to the dual action of a fee-incurring visit and auction, which HMRC was last year granted the powers to carry out

- ContractorUK

The Freelancer and Contractor Services Association (FCSA) has rejected a report from the Citizen's Advice Bureau (CAB) which claims around 460,000 people have bogus self-employed status nationwide

The FCSA said the report is an over-simplification of the real situation, and that the report did not make clear that bogus self-employment is disproportionately found among lower-paid workers

The nationwide figure given by the CAB does not appear to factor in this disparity

FCSA data indicates 48% of self-employed workers are higher-paid professionals, such as managers, directors and senior officials

The CAB report surveyed 500 of its clients who may or may not be representative of the workforce as a whole

Julia Kermode, chief executive of the FCSA, commented: "Whilst it is positive that the Citizen's Advice Bureau is exposing some very poor practices, we are concerned that today's report may lead to pressure for a knee-jerk response to what is actually a very complex issue

" The CAB report claims that many people are told they are self-employed when government tests would indicate otherwise

Employment status can be a grey area, as HMRC and the DWP use different tests to determine status

The CAB claims that bogus self-employment status costs the Exchequer '314m annually and that lower-paid workers potentially lose out on '1,288 annual holiday pay and pay '61 extra in National Insurance contributions

The CAB is calling for a review of the applicable rules to increase clarity

Julia Kermode of the FCSA said: "We strongly oppose any bad practice and we will continue in our efforts to help rid the industry of any rogue firms

" - FCSA "Working time" can include time spent travelling to and from home for workers with no fixed place of work The European Court of Justice ("ECJ") has today handed down an important decision for businesses with "field" based workers (those with no fixed workplace) holding that time spent travelling between a worker's home and a customer's premises is working time under the Working Time Directive ("WTD")

The press release is here and the text of the final judgement here

This decision does not impact on workers who travel to and from a fixed place of work, such as an office and which travel time does not count as "working time"

For those businesses with mobile workers, this decision raises questions as to whether existing working arrangements, such as resourcing and scheduling, now need to be changed bearing in mind the working time and rest requirements under the Working Time Regulations ("WTR")

Also, should this time be paid? The UK national minimum wage ("NMW") legislation appears on the face of it not to require minimum pay for travel time between home and a place of work

However, a legal challenge that this time should be paid in some shape or form cannot be discounted - see Unison's comment here

In the meantime, businesses may well in any event now face pressure to change employment contract terms to pay for this travel time or incorporate it within the core hours a worker is paid for

What did the ECJ say? The case before the ECJ involved a group of peripatetic workers who had formerly worked out of a now closed regional office

They brought a claim in Spain arguing that their employer was in breach of the working time rules in calculating their working day as starting from arrival at their first assignment and ending when they left their last assignment, rather than from leaving their home to travel to the first assignment and arriving back at home from their last assignment

The Spanish court referred the matter to the ECJ

The ECJ has held that for workers such as these, the time spent each day travelling between their homes and the premises of the first and last customers "designated by their employer" constitutes "working time" within the meaning of the WTD

The journey was a "necessary means of providing those workers' technical services" to the customers

To only take the time spent carrying out the activity of installing and maintaining the security systems would "distort" the concept of what was "working time" and "jeopardise the objective of protecting the safety and health of workers"

This was reinforced here by the fact that prior to the closure of the regional office, journeys from the regional office to the first customer and back to the regional office from the last customer were part of their activity or duties

They were "placed in a situation in which [the worker was] legally obliged to obey the instructions of his employer and carry out his activity for that employer"

Here the ECJ found that during the necessary travelling time the workers were not able to use their time freely and pursue their own interests

An employer might change the order of the customers or cancel or add an appointment during the journeys and the workers would act on those instructions

The ECJ considered that concerns that time for such journeys could be abused could be dealt with by putting "in place the necessary monitoring procedures to avoid any potential abuse", which, whilst an additional burden for the employer here, was an "inherent consequence of its decision to abolish the regional offices"

The ECJ followed the Advocate General stating that given that travelling is an integral part of being a worker without a fixed or habitual place of work, the place of work of such workers cannot be reduced to the physical areas of their work on the premises of the employer's customers

The ECJ again alluded to the employer's decision to close its regional office commenting that "having lost the ability to freely determine the distance between their homes and the usual place of the start and finish of their working day, [the workers] cannot be required to bear the burden of their employer's choice to close those offices

" Again this would be contrary to the objective of protecting the safety and health of workers required by the WTD

Whilst the ECJ's decision clearly focuses on the specific facts of the case before it and is arguably assisted by the ability to compare the arrangements prior to the closure of the regional office and after, it is clear that the three elements required for time to be "working time" under the WTD may be met in a variety of situations

e

those who have no fixed base) must now carefully review the working arrangements for these individuals bearing in mind that travelling time from home to the first customer of the day and to home from the last customer may well now be considered to be working time under the WTR

Inevitably there will be grey areas in determining whether an individual's travel time is working time which employers will need to grapple with on a case by case basis

Questions to consider include: o What is the position where a worker is not operating to a schedule of customers and times designated by his employer? The employer's control in this respect appears to be a key element in the ECJ's decision that the workers were not able to use the time freely to pursue their own interests and were at the employer's disposal

o Is the position different where a worker uses his or her own vehicle rather than a company one? Does it matter if the employer has no means of contacting the worker during the travel time? Whilst these facts were highlighted in the case before the ECJ, these issues were not of themselves determinative

What they do demonstrate is that determining whether a worker meets the requirements for journey time to be working time should be explored within th

This should ensure that people who make errors over relatively small sums of tax do not get caught by the offence which, for now, will apply just to income tax and capital gains tax

But the Chartered Institute of Taxation (CIOT), which called for safeguards earlier this year, says its main concern on behalf of taxpayers still stands

A taxpayer may fall within the ambit of the offence without any intention or knowledge on their part

The same document states that the offence will be triggered in three ways - failing to notify HMRC of chargeability of tax; failing to file a return and filing an inaccurate return

- ContractorUK

George Osborne would risk a revolt from his own parliamentary colleagues if Autumn Statement 2015 contains a reported plan to ban PSC contracting for more than a month

In fact, “a number of politicians” would likely challenge the chancellor if he unveils the ‘one-month-then-payroll’ clause on November 25th, says the Freelancer & Contractor Services Association

The employers’ group, the CBI, which will apparently have a say on the reported plan at its annual conference this week, would likely object too, believes FCSA chair Julia Kermode

“There are some 4

6m self-employed workers in the UK who will have to go on the payroll of each of the clients they work for after a month if this [reported] legislation comes into force,” she said

“That is a huge administrative burden for UK plc who will suddenly find themselves having to deal with a significant amount of workers on the payroll”

Kermode spoke of the “statutory benefits” which, presumably, would accrue and be payable to the worker by the employer, in the event that 'off-payroll' PSCs become taxed like 'on-payroll' employees

The Association of Independent Professionals and the Self-Employed says it is urgently trying to clarify whether an effective ‘one-month’ cap on contracting is “under serious consideration

” “This would make operating a freelance business almost impossible in many instances, and would cause untold damage to the flexible economy,” warns IPSE chief executive Chris Bryce

“This measure was not contained within the government’s original consultation documents and has not been raised by the government with stakeholders in its regular IR35 Forum meetings

” But nasty surprises are what the contractor industry has had to get used to, and more ‘devil in the detail’ is likely - even if the one-month cap comes to nothing, a services provider said last night

It warned: “[We] don't think anything will be said of much interest to contractors and how they are paid in the Autumn Statement

Eyes should be on the 2016 Finance Bill and not just the amendments we know about”

However, another services provider says the current concern about how contractor pay levels will suffer under the chancellor’s proposals – like the new dividend tax and ‘SDC’ or the ‘one-month cap’, is misguided

Carolyn Walsh, a director at CWC Solutions told ContractorUK: “Many organisations that represent or provide services to contractors…have said that they believe they will suffer losses and that contracting 'won't be worth it in future'

“But if perceived losses are down solely to paying more tax in future, that's not really a business issue, more a concern over take-home pay and I propose that this is a counter-productive argument

“In practice, genuine business-owners concern themselves with gross profit; being overly concerned with net pay could leave some contractors with a question mark hanging over their contractor status if a more business-like approach to the expected changes is not taken

” The FCSA suggests that such a question mark is already there - at least in the Revenue’s eyes

“HMRC is intent on ‘making IR35 more effective’” said Ms Kermode

“[This] means collecting more tax for the chancellor and levelling the field between [an employer’s] direct employees and their workers

"It's an utter nonsense and from discussions I have had with a number of politicians there is no political will to support Osborne on this move - I cannot see the CBI being in favour of it either

" She added: “We are very worried that hirers will simply not engage freelancers and contractors at all which will defeat the whole purpose of a flexible freelance workforce which is enabling businesses to be agile – it is unthinkable that government might be prepared to jeopardise this with an ill-thought-through move

"

A new approach to IR35 has been put forward to HM Revenue & Customs ahead of the chancellor’s Autumn Statement next month

Outlined by the Chartered Institute of Taxation, the approach rejects the ‘Supervision, Direction or Control’ test in favour of an annual reporting obligation on end-users

Based on each PSC contractor initially assessing whether or not IR35 applies, the end-user would then take that assessment and report to the Revenue whether or not it is in agreement

If the end-user was to “wilfully” mislead HMRC that IR35 did not apply, when in fact it did, then any debt owed by the PSC under IR35 would “fall back” to the end-user, the CIOT said

This approach would be better than ‘SDC’ because, under such an “inherently subjective test”, many PSCs who are “genuinely in business for themselves” would be wrongly caught

So SDC would be contrary to an aim of the IR35 discussion document – not to widen IR35’s scope

It wouldn’t simplify administration, nor would it cut non-compliance, CIOT added

It also believes that HMRC should accompany the new reporting obligation with a campaign to “give greater publicity to their successes in IR35 cases”, to increase awareness of the rules

The CIOT’s Colin Ben-Nathan said: “It is clearly wrong that some people get away without paying the correct amount of tax and NICs because they are playing fast and loose with IR35 either through ignorance of the rules or deliberate non-compliance

“We strongly recommend that the annual reporting option we propose is seriously explored by HMRC rather than imposing an obligation on businesses to account for tax and NICs at source on payments to PSCs, as put forward in the discussion document

The Association of Professional Staffing Companies (APSCo) has responded to today’s Autumn Statement highlighting the expected changes to travel and subsistence rules, but also commenting on an even more important absence, and one which represents a hiatus for the professional recruitment sector in the UK

IR35 changes APSCo welcomes the Government’s lack of action on IR35

Following recent reports leaked to the media regarding far-reaching changes to the legislation, APSCo was expecting material which could have seriously impacted on the professional recruitment sector

However, it appears that, following the overwhelming negative response from business as a whole and a rigorous press and lobbying campaign by APSCo, the Government has chosen to think more carefully about the unintended consequences of the proposals

Commenting, Samantha Hurley, Head of External Relations and Compliance at APSCo says: “We understand now from HMRC that the Government is still considering responses to their discussion document

APSCo strongly protested against the proposals, leaked a couple of weeks ago, and it seems that the Government has listened to our concerns about damaging the professional, flexible labour market in the UK with a knee-jerk reaction

We will continue to work with the Government to find the best solution for the Exchequer and British business

” “Of course, the lack of an announcement in the Autumn Statement doesn’t mean that the Government won’t go forward with this proposal in the future, but it does almost certainly mean that it won’t come into effect in April, 2016, which is what we feared

” Changes to Travel and Subsistence Rules APSCo will also be briefing its members on the changes to the travel and subsistence rules for individuals working through intermediaries, who will no longer be eligible for tax relief on their expenses unless they pass the test of being genuinely self-employed

Commenting on these changes, Samantha Hurley said, “The Chancellor confirmed what we thought that the government will legislate to restrict tax relief for travel and subsistence expenses for workers engaged through an employment intermediary, such as an umbrella company or a personal service company

This change will take effect from 6 April 2016

Unfortunately, it appears that we will have to wait until the 9th December for the draft legislation to be published, before we will know the full details of the test that will be used to decide on someone’s employment status for tax purposes, and therefore whether they are able to claim tax relief on their expenses

” Business Rates APSCo welcomes the further support given to small business in the form of the extension to the doubling of small business rate relief (SBRR) in England for 12 months to April 2017

“The majority of recruitment firms in the country are SMEs and it is pleasing to see that many will continue to receive 100% relief from business rates,” added Hurley

This is being attributed to crippling delays in receiving end-of-year tax refunds

Data obtained by accountant Nixon Williams under the Freedom of Information Act reveals that 105,000 construction businesses were registered for gross payment in 2014/15, the highest level in four years

At the same time, the number of construction businesses declined by 0

6%, from 253,121 to 247,105, although that number has increased again slightly in the past year

According to Nixon Williams, more builders are choosing to register for gross payment status under the Construction Industry Scheme (CIS) due to worsening delays at HM Revenue & Customs paying annual tax refunds, despite making a commitment to do so in 25 working days

CIS subcontractors often overpay tax, and in many cases they are waiting six months or more, for refunds worth tens of thousands of pounds, which is causing cashflow problems, and even pushing some towards bankruptcy

Subcontractors who register for the CIS have 20% of their pay deducted by contractors and handed over to HMRC, while unregistered subcontractors have 30% of their pay deducted by contractors

Subcontractors can, however, apply for gross payment status when they register for CIS

This means contractors pay them in full, without deductions

Subcontractors then pay all their tax and National Insurance at the end of the tax year

Gross payment status imposes a heavier compliance burden on subcontractors, and so many do not register

HMRC has promised a 25-day turnaround target for tax repayments but with staffing levels having been cut, and additional security checks imposed, that 25-day deadline is almost never met

Nixon Williams practice manager Daniel Knowles said: “Delays receiving tax refunds of six months or more are becoming increasingly common

This is hurting the cashflow of many subcontractors, and in some cases impeding their ability to conduct business

“As a result, growing numbers of subcontractors are being advised to register for gross payment status, allowing them to better manage their cashflow and avoid lengthening delays obtaining tax refunds

It is very common for subcontractors to have paid too much tax, and the last thing they need is to have to wait months and spend time chasing HMRC to get the money back

” He adds: “Gross payment status was sometimes regarded as a mixed blessing

It allowed subcontractors to manage their own tax affairs but at the cost of a higher administrative burden and an annual review by HMRC

With delays over tax repayments mounting, growing numbers of subcontractors are realising that the extra hassle is now well worth the effort

The chancellor made a U-turn on controversial cuts to tax credits but there was no reversal of plans to scrap tax relief on travel and subsistence expenses for freelance workers

Tax changes next April will cost self-employed workers an average of £200 a week each Above: Tax changes next April will cost self-employed workers an average of £200 a week each And this means a likely pay cut next year for all those construction workers who are either genuinely self-employed or technically employed by umbrella companies

Research by umbrella firm Danbro suggests the move could cost each freelancer an average of £200 a week when tax relief is scrapped in April 2016

Danbro managing director Damian Broughton said: “The chancellor started by saying this was a budget that would deliver what businesses need – competitive taxes

The reality is that he’s raided the pockets of contractors and businesses alike with a cynical stealth tax

“This move could have a potentially devastating effect on some businesses that rely on freelance workers to provide the skills they need

If they want contractors to come to their site they will have to pay much more – many won’t have the capacity to do that

“The chancellor also heralded the growth we’ve seen in the UK economy over recent years

That growth was fuelled by our flexible workforce and he’s now putting the brakes on this vital sector by stopping them from travelling to where they are needed

” The decision to restrict tax relief for travel and subsistence expenses for workers engaged through an employment intermediary, such as an umbrella company or a personal service company will raise just £265m for the Treasury, Mr Broughton said

Mr Broughton added: “While the autumn statement brought good news for contractors in the shape of numerous infrastructure and building projects, this short-sighted tax grab will hit the temporary worker sector hard

“The chancellor repeatedly claimed ‘we are the builders’, but without a strong flexible workforce we won’t be able to build anything

” Controversy creates unlikely bedfellows: construction union Ucatt has been waging a strident campaign against umbrella companies for the fees that they charge, but is with full agreement with Damian Broughton on this one

Ucatt acting general secretary Brian Rye said: “This is a kick in the teeth for workers who are already losing thousands of pounds a year by being forced to work via an umbrella company

” He said that expenses form a legitimate part of construction workers’ take home pay as they recompense them for having to travel to temporary sites and often have to work away from home

Ucatt believes that legitimate expenses should be paid on top of wages and not used to bulk out wages

Mr Rye added: “This is effectively a pay cut and means that construction workers will be unable to make ends meet or afford life’s extras which are often the only recompense for working long hours in a hard unforgiving environment

HM Revenue & Customs has launched online tax accounts as part of a wider plan to make all taxes digital by 2020

A bit like online banking accounts made monthly statements irrelevant, the Personal Tax Account could see an end to yearly tax returns, according to HMRC

“Remember when you started online banking? Well, this is the equivalent shift in service for the majority of our customers wanting to do business with us online,” said Ruth Owen, Director General of Personal Tax

The Personal Tax Account will consolidate information from employers, banks, building societies and other government departments so that taxpayers won’t have to hunt for all of the information and add it themselves

It will update in real time, showing you what you need to pay and what you’re owed

You can also update information without having to submit lengthy forms

And, if you get confused, it has a virtual assistant and web chat

“We’ll be developing the Personal Tax Account further so it will become the one place to go for all our customers to do business with HMRC,” explained Owen

But this year - while tax returns are still an annual burden - more than a million taxpayers will be directed to the online system to complete their self-assessment for the taxes that don’t come out of your pay slip

“This government is determined to revolutionise how we deliver public services and the tax system is no exception,” said David Gauke, the Financial Secretary to the Treasury

This is the second stage of HMRC’s plan to overhaul the tax system, which has been facilitated by £1

3 billion of extra investment from the government, announced in the Autumn Statement

Last year HMRC launched an online system for business tax accounts, which is already being used by 2

2 million businesses

And it plans to roll out the accounts to all businesses by April 2016

By 2020 the full range of HMRC services should be available through digital tax accounts

The five year plan has been released a month after HMRC announced it was closing its 170 offices across the country and moving them into 13 regional hubs

Up to 56,000 staff could be made redundant as a result of the slimming down

Digitising the tax system should eradicate unnecessary form-filling and put all tax information in one place, according to HMRC’s “Making tax digital” report

It is expected that businesses and individuals will use the service to register, file and pay taxes, and change their personal information

Article courtesy of The Telegraph

A report by Oxfam estimates tax cheats have cost the Treasury £5bn in lost revenue

The charity believes more than £170bn owned by the wealthiest Britons is being held offshore in locations such as the Cayman Islands and Bermuda, costing the exchequer £5bn in lost taxes every year

Oxfam’s research also indicates the richest 1% of Britons, a group solely comprising of millionaires, have received more than a quarter of the £4trn increase in national wealth since 2000

In addition, it reveals men have benefited far more from tax cuts for top earners than women

Cutting the top rate from 50p to 45p four years ago helped 16% of women but 84% of men, the research suggests

Sources - Daily Mail, The Guardian, The Independent, Daily Mirror,

Leading business groups have urged George Osborne to refrain from a tax raid on companies in his bid to achieve a budget surplus by the end of the decade

The BCC has told the chancellor to hold off from imposing more "burdens for business" when he delivers his Budget on Wednesday

"At a time when many businesses already face sharply higher costs and taxes, the chancellor must avoid adding any new obligations on our firms," said Adam Marshall, acting director general of the BCC

Source - The Daily Telegraph,

The flexible workforce has been the victim of one attack after another from HMRC, with the consultations around removing the benefit of travel and subsistence expenses for umbrella employees working under supervision, direction or control of the End-client being the most recent

That said, Financial Secretary to the Treasury, David Gauke recently wrote, 'Flexible labour plays an important role in the UK economy and in ensuring business has access to the individuals, skills and services it needs to encourage growth and rapidly respond to new demands

It is an important aim of this government to ensure that the tax system reflects the key role flexible labour now plays in the UK and how businesses and labour markets are operating

' 'Recognising the different ways individuals are now working, whilst ensuring the tax system provides no individual or business with an unfair advantage

We are committed also, to ensuring the tax system is not exploited by businesses and individuals seeking to pay less tax and are continuing to tackle tax avoidance, tax evasion and address unfair outcomes as a priority

' It�s clear that government have got the tough job of balancing the needs of businesses to remain competitive whilst not allowing tax revenue to fall between the cracks, especially through the use of contrived tax avoidance models that are so widely available, and actively marketed by certain Umbrella Companies and industry service providers

Talk to Genius about how HMRC view Umbrella

A tax tribunal has ruled against a stamp duty land tax (SDLT) avoidance scheme used by Crest Nicholson, one of the UK’s largest house builders, meaning it will have to pay the £1

3m it owes

HM Revenue & Customs (HMRC) challenged the artificial and complex arrangements made by the FTSE 250-listed company to avoid paying SDLT on three purchases of development land near Rochester in Kent for a total of more than £32m

The avoidance scheme sought to use the transfer of property between two sub-companies to avoid the tax

The First-tier Tribunal decision is likely to have an impact on more than 700 other cases, potentially protecting £65m of taxpayers’ money, HMRC said

Crest Nicholson argued that HMRC did not have a legal right to make assessments of the tax due because it was out of time to do so, and that it had not carried out its assessments properly

The judge disagreed with these arguments and found that HMRC had acted correctly throughout

The judgment reflects HMRC’s tribunal victory in the Vardy case in 2012, when it challenged a similar SDLT avoidance scheme based on complex sub-sale arrangements

HMRC director general, customer compliance, Jennie Granger, said: “This decision makes it clear that setting up artificial and complex arrangements involving sub-companies to avoid paying tax doesn't work

It's another important success that’s protected taxpayers’ money

This win sends a clear message that tax avoidance is expensive and self-defeating

” HMRC challenges every tax avoidance scheme it comes across and has a strong record of defeating schemes

When taxpayers choose to litigate, HMRC wins about 80% of avoidance cases heard in court, though many more scheme users choose to settle before reaching this stage by paying all the tax due

The bill for Spurs’ new stadium has gone up from £400m to £800m, the club has said, with the fall in the pound adding 20% to construction costs

"It's worth remembering that the original cost quoted for the stadium was some seven years ago,” executive director Donna Cullen emailed a fan, HotspurSam

“This new 'estimated' figure relates predominantly to the stadium with some elements of substructure for the other builds particularly the Tottenham Experience

" The email was posted on www

skyscrapercity

com, where there is a forum dedicated to scrutinising the details of the project

In it, Donna Cullen says: “Brexit has added a straight 20% on costs for foreign goods due to the exchange rate, overtime working and increased construction costs similarly

Revised basement works also added to the cost

We are constantly managing costs and will continue to do so throughout the process along with funding plans to ensure the viability of the scheme

" Meanwhile new photos released by the club reveal substantial progress with the build programme

An estimated 3,000 construction jobs are expected to have been delivered by the time the new stadium opens in August 2018 and 72,000 m2 of concrete will have been poured

Spurs’ new stadium is being built adjacent to its current White Hart Lane home, with Mace as main contractor

Designed by Populous, it will have a capacity of 61,000, incorporating the UK’s largest single tier stand, the home southern end, which will be able to hold up to 17,000 spectators

It will also have a retracting pitch to make it suitable for American football after the club signed a commercial deal with the NFL

Spurs chairman Daniel Levy has described the project as "the most complex private build in Europe at this time"