Newsletters

Trustees disposing of shares in a trading company

A recent First Tier Tribunal case found that trustees of a UK resident trust were entitled to pay CGT at 10% rather than 20% on a disposal of shares, READ MORE
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Property held through Non-UK companies – trustees need to be ready

One aspect of the taxation of non-UK companies was previously straightforward: they were generally not chargeable to corporation tax. READ MORE
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HMRC’s “nudge” tactics expand to rental income

We have published four articles in which we focused on HMRC’s increasing use of so-called “nudge letters”,  READ MORE
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How much can you save if you register for the Profit Diversion Compliance Facility before you’re “nudged”?

We’ve recently published three articles on HMRC’s use of “nudge” letters in various contexts. HMRC are expected to issue another batch READ MORE
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HMRC “nudge letter” on overseas income and gains in more complex circumstances

In our first article dated 22nd August 2019, we considered the increase in the issue of nudge letters by HMRC which seek to challenge Read More
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HMRC “nudge letters” about overseas income and gains

In this, the first of two related articles, we consider the issue of so-called “nudge letters” by HMRC challenging the accuracy of UK tax returns, READ MORE
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HMRC enquiries into cryptocurrency profits – will there be “nudge” letters?

There are press reports that HMRC has written to the main cryptocurrency exchanges READ MORE
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Company residence Tribunal case – the importance of independent decision making

A recent Upper Tier Tribunal case serves as a reminder of the importance for the directors of non-UK companies to be able show that they have acted independently in the management of the company. Read More
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Staleness: HMRC found to be past its sell-by date

Discovering that something is stale is usually accompanied by disappointment. READ MORE
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HMRC’s Profit Diversion Compliance Facility

In January 2019 HMRC introduced the Profit Diversion Compliance Facility (“PDCF”). READ MORE
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