Gosh, so many things; I am not sure I have seen such an exciting time for tax in my career. As clients start to look ahead to the post-lockdown landscape, we are working closely with them to reshape their businesses to build in efficiencies whilst also to ensuring they are fit for the current tax environment.
Since becoming head of tax for Mazars in the UK in January, I have been working with the teams to become even more closely aligned with our clients, and allow everyone in our team to reach their full potential.
If you could make one change to tax, what would it be?
A greater alignment between administration within tax authorities and the way businesses operate. A simple example of the difficulties created by the lack of alignment would be the process for obtaining things like tax residence certificates. Delays in obtaining these hold up businesses from being paid by their clients, which has the potential to cause longer term damage for businesses where cashflow management is key. Another example would be the range of different tax governance requirements with different thresholds, making the system complex to comply with.
What do you know now that you wish you’d known at the start of your career?
You can’t know everything and it’s absolutely fine to say so, but the key is to surround yourself with people who will roll up their sleeves and help you find the answer.
Has a recent tax case caught your eye?
Although I am absolutely not a VAT practitioner, I have been discussing with our teams some of the recent significant cases concerning VAT on the one hand and tax accounting on the other. These do seem to highlight an imbalance in the system such that taxpayers with genuine business reasons, or who try their best to understand complex tax systems, need to go to great expense to get a fair result. Recent cases with implications for VAT on property transactions are illustrated by Balhousie Holdings Ltd [2021] UKSC 11 and Colchester Institute Corporation [2020] UKUT 368 (TCC). On tax accounting, I am looking forward to the Supreme Court’s hearing of the NCL Investments Ltd case, and a forthcoming First-tier Tribunal decision on the deductibility of deferred revenue expenditure in connection with a property disposal. These cases also illustrate the complexities in deciding whether a tax position is certain from both the taxpayer’s and HMRC’s perspective.
Are there any new rules that are causing a particular problem?
While it is helpful the threshold for the requirement for large business to notify uncertain tax positions has been increased, there is, I believe, further work that could be done to define uncertain tax positions to make this workable for businesses. The projected tax yield from this measure also seems to indicate that it will come from very few taxpayers, imposing significant compliance burdens on the majority who are already compliant.
What should we look out for later this year?
I suspect there will be a flurry of activity from the withdrawal of effect on withholding tax of the EU Interest and Royalties Directive for UK outbound interest and royalty payments in June this year. Whilst we are raising it with clients, at the moment there is so much to focus on at a business level that I fear it will have slipped down the priority list and we will find a backlog at HMRC.
You might not know this about me but...
We were lucky enough to move house at the end of lockdown 1.0, and the room I have been working in since has a fantastic view over the garden and fields. I have become somewhat obsessed with the variety of bird life that visits and have been known to interrupt Teams meetings to share my excitement at seeing something new – much to the hilarity of the team and pretty much everyone who knows me!
Gosh, so many things; I am not sure I have seen such an exciting time for tax in my career. As clients start to look ahead to the post-lockdown landscape, we are working closely with them to reshape their businesses to build in efficiencies whilst also to ensuring they are fit for the current tax environment.
Since becoming head of tax for Mazars in the UK in January, I have been working with the teams to become even more closely aligned with our clients, and allow everyone in our team to reach their full potential.
If you could make one change to tax, what would it be?
A greater alignment between administration within tax authorities and the way businesses operate. A simple example of the difficulties created by the lack of alignment would be the process for obtaining things like tax residence certificates. Delays in obtaining these hold up businesses from being paid by their clients, which has the potential to cause longer term damage for businesses where cashflow management is key. Another example would be the range of different tax governance requirements with different thresholds, making the system complex to comply with.
What do you know now that you wish you’d known at the start of your career?
You can’t know everything and it’s absolutely fine to say so, but the key is to surround yourself with people who will roll up their sleeves and help you find the answer.
Has a recent tax case caught your eye?
Although I am absolutely not a VAT practitioner, I have been discussing with our teams some of the recent significant cases concerning VAT on the one hand and tax accounting on the other. These do seem to highlight an imbalance in the system such that taxpayers with genuine business reasons, or who try their best to understand complex tax systems, need to go to great expense to get a fair result. Recent cases with implications for VAT on property transactions are illustrated by Balhousie Holdings Ltd [2021] UKSC 11 and Colchester Institute Corporation [2020] UKUT 368 (TCC). On tax accounting, I am looking forward to the Supreme Court’s hearing of the NCL Investments Ltd case, and a forthcoming First-tier Tribunal decision on the deductibility of deferred revenue expenditure in connection with a property disposal. These cases also illustrate the complexities in deciding whether a tax position is certain from both the taxpayer’s and HMRC’s perspective.
Are there any new rules that are causing a particular problem?
While it is helpful the threshold for the requirement for large business to notify uncertain tax positions has been increased, there is, I believe, further work that could be done to define uncertain tax positions to make this workable for businesses. The projected tax yield from this measure also seems to indicate that it will come from very few taxpayers, imposing significant compliance burdens on the majority who are already compliant.
What should we look out for later this year?
I suspect there will be a flurry of activity from the withdrawal of effect on withholding tax of the EU Interest and Royalties Directive for UK outbound interest and royalty payments in June this year. Whilst we are raising it with clients, at the moment there is so much to focus on at a business level that I fear it will have slipped down the priority list and we will find a backlog at HMRC.
You might not know this about me but...
We were lucky enough to move house at the end of lockdown 1.0, and the room I have been working in since has a fantastic view over the garden and fields. I have become somewhat obsessed with the variety of bird life that visits and have been known to interrupt Teams meetings to share my excitement at seeing something new – much to the hilarity of the team and pretty much everyone who knows me!
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