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Thank you for your question. I assume your reference to SPS is the agricultural subsidy payment, now known as the BPS (Basic Payment Scheme)?
That being the case please can you confirm whether these payments were made to you as an individual or to a limited Company? Likewise, is HMRC now referring to these payments as personal income for income tax purposes or are they suggesting that this will impact on a corporation Tax assessment?
Once you have replied I should be able to deal with your query fairly quickly.