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31 August 2017 – A key date for the diary

A reminder to all tax advisors or financial institutions, that they must write to their clients on or before 31 August 2017 to advise that HMRC will shortly start receiving financial information regarding UK residents from overseas jurisdictions via the Common Reporting Standard. read more 
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Recent domicile case goes in HMRC’s favour (unsurprisingly)

A recent First Tier Tribunal (Henderson [2017] UKFTT 0556 (TC)) has dismissed an appeal from four appellants that they were non-UK domiciled. Read more.
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First ever decision of the GAAR panel supports HMRC

On 3 August the first ever decision of HMRC’s General Anti-Abuse Rule (GAAR) panel was published. The panel decided in favour of HMRC in relation to arrangements which were designed to reward two employee/shareholders using gold, involving an Employee Benefit …
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HMRC FOCUS ON DOMICILE ENQUIRIES

As many non-doms become deemed domiciled in the UK, HMRC are taking the opportunity to challenge their historic domicile status. A notable increase in domicile enquiries from HMRC appears to confirm our understanding that HMRC is dedicating specific resources to …
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HMRC tax investigations – the yield dichotomy?

A recent report has concluded that yields against expenditure on HMRC investigatory staff have fallen by up to 17% in the last tax year. Read more
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Updated deemed domicile legislation published

The Treasury has published updated draft legislation for the planned changes to the taxation of non-UK domiciles. The big news is that the changes will be effective from 6 April 2017 and will not be rolled forward to 2018; bad …
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New draft tax rules from the EU Commission

which will mean financial advisors and other professionals face heavy fines if they are found to have helped individuals or companies cut their tax bills by using “aggressive tax planning schemes”. READ MORE
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UPDATE: HMRC & CLAVIS / HERALD

HMRC investigations into companies which used the “Clavis / Herald SPT” tax avoidance scheme Around August 2016, HMRC made the decision to transfer responsibility for all enquiries into the use of the Special Purpose Trust (“SPT”) tax avoidance scheme promoted …
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Landmark decision in Rangers EBT case

The Supreme Court has ruled unanimously in favour of HMRC in the long running legal battle with what was the Rangers Football Club (“RFC”) prior to 2012. Some of the most important consequences of the decision for companies which have …
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Tax forecast post-General Election

Following the June election and the recent Queen’s Speech the outlook from a tax perspective remains very unclear. READ MORE
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