The Knowledge Hub

HMRC’s revised settlement terms for disguised remuneration cases remain unpublished, despite earlier indications that they would be released in the spring. For affected taxpayers and advisers, the continuing delay is frustrating and prolongs uncertainty in an area already marked by significant financial and personal strain. This update considers why revised, workable settlement terms are urgently needed, the unresolved issues arising from HMRC’s 2020 settlement approach, and the hope that the eventual guidance will provide a clearer and more pragmatic route to resolution.

HMRC can issue information notices to UK taxpayers outside the UK, but the practical risks often lie less in the validity of the notice and more in how the enquiry develops.

The Court of Appeal’s decision in HMRC v Bolt Services UK Ltd is not just a private hire vehicle case. It is a reminder that the Tour Operators Margin Scheme is a narrow VAT exception, not a general margin scheme for businesses that buy in and resell travel-adjacent or accommodation-related services. For businesses that have applied TOMS outside a conventional travel agency or tour operator model, the decision should prompt a careful review of the historic position, current VAT treatment, and exposure to future HMRC enquiry.