Blog Archives

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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Tax Investigations

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HMRC plots a route to CGT success

A recent tax tribunal case has confirmed that an individual was liable to CGT on an off-plan property sale throughout their period of ownership, notwithstanding that part of the period included a time when the property had not yet been built. This ruling confirms that private residence relief turns on occupancy and that, broadly speaking, purchasers will only qualify for PPR for those periods of actual occupation. This ruling is significant for those who buy off-plan properties because it may be some years before the property is built and the new owners can move in.This ruling may not help to calm the nerves of the shareholders of some of the UK’s largest housebuilders, whose share prices have all wobbled in the last few days following Teresa May’s announcement that the Government intends to introduce a new SDLT surcharge on non-UK resident purchasers.

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