Max Schofield

Wasn’t “Make Britain Great Again” a 1950s slogan?

I really don't understand why the Gov.uk website (designed to carry high traffic and peak loads) has chosen to link to the KC Appointments site (Standard Wordpress. Peak loads on one day a year) instead of just putting it on the Gov.uk site as a list or a PDF.

EV rules of origin, CAM, and why tariffs still don’t bite Starting the year as I mean to go on ...

MFN is back with a bang!

(Yes, I am talking about EU-UK electric vehicle rules of origin, obviously.)

mostfavourednation.substack.com/p/ev-rules-o...

In typical LinkedIn vernacular, "I am delighted to announce" that I (with Julian Ghosh KC) will be responsible for teaching the VAT portion of the undergraduate module Tax and Tax Avoidance at LSE this term, appointed as a guest teacher in the Law School alongside my usual practice at the Bar.

Merry Christmas all! 🎄

Many people starting to clock-off for Christmas this evening. Quite right too as Hans Gruber is close to his ultimate demise on my favourite advent calendar.

The New Claire Wine v HMRC appeal is being heard by the UT tomorrow on the question of whether “deliberate”, used across various taxing statutes, interpreted by the UKSC in Tooth, imputes dishonesty and its associated procedural safeguards. I’m acting for the taxpayer, led by David Bedenham KC.

Please share: The Devereux Chambers Tax Essay Competiton is now live for students and grads.

This year, it’s the thorny topic of VAT and buildings/construction. (No prior tax knowledge required.)

First prize is £750 and a mini-pupillage in chambers.

www.devereuxchambers.co.uk/resources/Ev...

From the earlier OBR leak: private hire vehicle operators to be excluded from TOMS from January 2026. Yet to be mentioned… #VAT

Where can you find Luther Vandross, Aristotle, and the President of the Tax Tribunal all in one place? My dream dinner party guests? In fact, all feature in my article "Mix up with a fix up" about the Court of Appeal's recent judgment in Mudan v HMRC [2025] EWCA Civ 799. #SDLT

No change for VAT. Excepted Item 2 includes “biscuits… covered with chocolate or some product similar in taste and appearance”. I note the proliferation of TimTams in the U.K. which are not chocolate coated but have a “chocolatey flavoured coating” -may have influenced decision?

For Radio 4 addicts such as myself (although “I am much younger than their core demographic” to quote Glenn Cullen), check out ep.1 of The Tax Conundrum. Monday at 11am.

I should add: only a small proportion of my living is made arguing about food, and not about marshmallows.

@seanjones.org sorry to bother you but can I have the Billable Hour link for one humble brag pass please?

(There should also be a fine for C&P’s pleonasm with “VAT tax”)

I think in Amsterdam, there were even WhatsApp messages saying they were going to hunt Jews, which rather points away from Israeli fans being the cause. www.telegraph.co.uk/world-news/2...

The day before, the directors of PPE Medpro started the process of putting the company into administration. Administrators will seek to wind the company up and try to recover as much money as possible for creditors.

The BBC doing its best to aggravate all insolvency specialists this morning with a description of administration which is somewhat removed from the statutory purposes...

www.bbc.co.uk/news/article...

@drtribeinsolvency.bsky.social

James Bond reference in the opening paragraph of this family case about tracking devices for children.

Planning opportunity? #VAT 😂

RIP Danny Thompson. A musician’s musician with a body of work so diverse it covers artists from Kate Bush to Sonny Terry & Brownie McGhee and even the Thunderbirds theme tune. His appearances on the Transatlantic Sessions with Jerry Douglas on BBC4 are wondrous.

(Post Script: this is mostly an issue arising out of the VAT registration threshold. Economists and policy experts agree that the threshold should be far lower. That would be even more palatable if digital tax returns were easy and accessible to lower the admin burden.)

It is far more likely there will be a change in the regulations and some VAT guidance to stop the anomalies in the current system, and make the PHV operators (taxi call centres, or app operator) the person who needs to account for VAT on supplies they arrange.

I assume it is that to which the headlines are now referring. I cannot imagine Labour will be making mini cab drivers charge VAT if they are under the registrations threshold, or make a special lower threshold for PHV drivers. Neither of those are remotely likely / workable.

According to the consultation, this may mean a new bespoke taxi margin scheme, or a lower VAT rate for taxis, or treating mini cabs outside of London in the same way as inside of London: i.e. operators are deemed to provide the supply, not the drivers, so VAT is chargeable.

Because of these differences (agency v cash; London v regions; margin v normal accounting) which cause uncertainty and complexity, the Treasury with HMRC and the Department of Transport are quite properly looking at fixes.

This means operators have to deal with potentially different treatment depending on the type of work, where they are licensed, whether they are tour operators etc.

This is full of complexity about the meaning and purpose of the tour operators scheme as well as the need for drivers not to be employees, and is still subject to live litigation, but makes the effective VAT rate far lower than 20% (probably closer to 5%).

A further complication is a special VAT regime: “TOMS”. Bolt (and Uber) argue they are like a tour operator providing transport. This means, if they are providing the transport, they MUST account for VAT only on their margin (with no input reclaim).

Within London however, the operators are held to be entering the contracts for all work - certainly on the licensing regulations which many are reading as influencing the VAT treatment too (that’s a separate discussion for another day). So, VAT is charged on the whole fare.

For agency work outside London, the PHV operator enters into the contract then sub-contracts drivers to fulfil the supply. Here, unlike above, the registered operator charges VAT on the fare. This doesn’t affect drivers who charge their fee to the operators (no VAT if not reg’d).

So, for cash work outside of London, the operator is like an introductory agent. This means VAT is charged only on the operator’s commission paid by the drivers for the introduction service, and no VAT charged by the drivers on the actual fare to customers.

It concerns: who provides the taxi service you book, the mini cab driver or the mini cab operator company? Most operator companies will be above the VAT threshold so have to charge VAT if they provide the supply, unlike drivers who are less likely to be VAT-registered.