Blog Archives

‘Tax Day’ – government continues its campaign to tackle non-compliance

Promoters of tax avoidance schemes HM Treasury’s reminder that the so-called “tax gap” is at a record low of 4.7% (of which tax avoidance only counts for £1.7bn – approximately 5.5% of the total) is timely and welcome.  HMRC has …

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Corporate residence of subsidiaries: Court of Appeal decision provides more questions than answers

Though the CA judges unanimously agreed that the UT’s reasons for overturning the FTT decision were flawed, the judges disagreed on whether the FTT decision might have been wrong for other reasons – an issue that was strictly out of …

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Litigation privilege does not apply to tax advice from accountancy firms, rules High Court

When provided by an accountancy firm, advice on how to structure your affairs for tax purposes is not protected by legal advice privilege, and it may therefore need to be disclosed in a subsequent HMRC investigation or in litigation. This …

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HMRC starts to investigate furlough abuse, & property businesses are a target

HMRC has started investigating employers it suspects of abusing the furlough scheme and property and construction businesses are firmly in its sights. Investigations are focused on businesses that deliberately or inadvertently allowed staff to work whilst on furlough and are …

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Post-Brexit sanctions and the high net worth individual

The short answer to the first of those questions is no. At its core, the Sanctions and Money Laundering Act 2018 (‘SAMLA’), under which the British regime will operate once the UK has left the EU, is a restatement of …

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Calls to Abolish CGT Entrepreneurs Relief – Should Business Owners Be Worried?

In what is becoming a near-annual sport, there are again renewed calls for the restriction or outright abolition of CGT Entrepreneurs’ Relief. The latest high-profile support for the move comes from Sir Edward Troup, previously the head of HMRC, in …

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Regularising Past Non-Compliance

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“IR35” and Consultancy Arrangements

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UK Residence

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Domicile enquiries

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