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Blog Archives
HMRC Loan Schemes: A New Settlement Approach for Individuals Caught Up in Disguised Remuneration (Autumn Budget 2025)
Carly Russell, Partner in our Private Wealth Disputes team, shares her initial thoughts on HMRC’s newly announced settlement approach for individuals caught up in disguised remuneration loan schemes. One area of interest in the 2025 Autumn Budget was the Government’s …
Posted in Shorter Reads
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Lessons from Angela Rayner’s SDLT errors
In the fast-paced world of politics, personal financial matters can quickly become public scrutiny magnets, often revealing tax law’s intricacies that most individuals, even politicians, will be blissfully unaware of. The recent controversy surrounding Angela Rayner, former deputy prime minister, …
Posted in Longer Reads
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Farmers and business owners seek Judicial Review of Inheritance Tax Changes to Agricultural/Business Property Relief
Leading Private Wealth law firm Collyer Bristow LLP served proceedings on the Chancellor of the Exchequer and HMRC on 23 June 2025 for a Judicial Review of the government’s decision not to consult on the planned Agricultural Property Relief (APR) …
Posted in News
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2025 Spring Statement
Overall Comment on the Spring Statement The Spring Statement reflects the Government’s continued focus on “closing the tax gap” through increased HMRC powers and enforcement activity. Many of the measures announced feel like an extension of existing policies rather than …
Posted in Shorter Reads
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Foreign Assets Ruling Suggests New Tax Avoidance Approach
On Nov. 21, the U.K. Supreme Court handed down its decision in Commissioners for His Majesty’s Revenue & Customs v. Fisher on the scope of the U.K.’s transfer of assets abroad, or TOAA, tax code, finding unanimously for the taxpayers …
Posted in Longer Reads
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Supreme Court rules against HMRC in family business case
The Supreme Court has today (Tuesday 21 November 2023) handed down its decision in the Fisher case on the scope of the UK’s “Transfer of Assets Abroad” (“TOAA”) tax code, finding unanimously for the taxpayers on every point. As Lady …
Posted in Longer Reads
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Is it illegal for me to pay my handyman in cash?
Is it illegal for me to pay my handyman in cash? Am I breaking the law paying in cash because I am facilitating tax evasion and leaving no paper trail? Would I be liable in any way if he gets …
Posted in Longer Reads
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COURT OF APPEAL JUDGMENT BRINGS LANDMARK HICBC CHILD BENEFIT CASE TO A SUCCESSFUL CLOSE
The Court of Appeal (Lords Justices Newey, Baker, and Arnold) has today handed down its judgment in HMRC’s appeal in the leading HICBC case (HMRC -v- Wilkes). The Court unanimously rejected every one of HMRC’s arguments, and upheld the Upper …
Posted in Longer Reads
Tagged HICBC, HMRC, Wilkes
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HMRC v Wilkes Approved Judgement 07.12.2022
A PDF copy of the Court of Appeal’s judgment.
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