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Coronavirus (COVID-19)


This subtopic contains materials, commentary and analysis of the tax issues that arose, and may continue to arise, in relation to the outbreak of coronavirus (COVID-19).

Tax measures to address COVID-19

A number of tax measures were specifically introduced by the government in response to the COVID-19 pandemic. There are also areas of tax that were particularly relevant in this context. These measures include:

  1. •

    schemes to support the employed and self-employed, including the coronavirus job retention scheme (CJRS) and the self-employment income

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Latest Tax News

FTT considers meaning of interest and decides that an element of redress payments constituted interest (NHS Mid & South Essex ICB and others v HMRC)

Tax analysis: In NHS Mid & South Essex ICB and others, the First-tier Tax Tribunal (FTT) decided that an element of the NHS continuing healthcare (CHC) redress payments constituted interest for the purposes of section 874 of the Income Tax Act 2007 (ITA 2007) and, furthermore, that the interest constituted yearly interest or was treated as yearly interest under ITA 2007, s 874(5A) since the interest was payable to individuals in respect of compensation.

Tax weekly highlights—19 December 2024

This week's edition of Tax weekly highlights includes: (1) the House of Commons committee debating (but not amending) clauses of the Finance Bill 2025, (2) the NICs Bill passing the House of Commons stages without amendment, and (3) the Spring Forecast to be published on 26 March 2025.

FTT applies carried-forward losses anti-avoidance rule (Blackfriars v HMRC)

Tax analysis: In Blackfriars Hotel (UK) Holdings Ltd, the First-tier Tax Tribunal (FTT) held that the anti-avoidance ‘loss refresh’ provisions of Part 14B of the Corporation Tax Act 2010 (CTA 2010) applied to disallow relief for pre-April 2017 carried forward loan relationship deficits against profits arising from tax arrangements entered into by the company.

UT sets aside FTT decision on tax treatment of EBT arrangements (M R Currell Ltd v HMRC)

Tax analysis: In M R Currell Ltd v HMRC, the Upper Tribunal (UT) considered an appeal of the taxpayer company against a decision of the First-tier Tax Tribunal (FTT) that a director and shareholder of the taxpayer company received taxable earnings in circumstances where the company had made a contribution to an employee benefit trust (EBT) which then subsequently loaned an equivalent amount to the shareholder director. The UT set aside the decision of the FTT and re-made it, allowing the taxpayer company’s appeal.

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