Year: 2021

A family investment company (“FIC”) is a company established to help pass wealth to the next generation while enabling the founders to continue to exercise control over the assets. Business as usual In April 2019, HMRC established a dedicated team to review the use of FICs, to better understand the profile of those establishing them,…

The recent decision in Avonside Roofing Ltd v HMRC has raised questions over HMRC’s strategy in its approach to enquiries into a tax planning arrangement promoted by Clavis Tax Solutions 10-15 years ago. The appeal heard by the Tribunal concerned a formal information notice issued by HMRC to Avonside Roofing Ltd but the decision will…

“Staleness” is an argument used in recent years by taxpayers – with some degree of success – to persuade the Tribunal that assessments raised by HMRC are invalid.  The point of law concerns the discovery provisions within Section 29 Taxes Management Act. The legislation allows a Revenue Officer to make an assessment if broadly he…

HMRC were successful in a First Tier Tribunal case in January in a challenge to the “Aikido” tax planning strategy. Although the case was not a test case as such, if the taxpayers (Ms Clipperton and Mr Lloyd) have not appealed the decision within the time limit, it becomes a “final ruling” which allows HMRC…

HMRC can issue an assessment where an officer discovers that an assessment to tax is insufficient, a discovery assessment, if the officer could not reasonably have been expected to be aware of the insufficiency of the assessment on the basis of the information made available to them within the time limit for enquiring into the…

From 31st January 2021, a new British visa is available for Hong Kong British National (Overseas) citizens and their close family members. This serves to highlight a particularly unfortunate tax pitfall that can trip up the unwary. Based on our experience of HMRC’s approach, we think it is likely that HMRC will argue in many…

At the time of writing, Bitcoin is trading at $53,000 (over £37,000).

A few days ago, its value reached an all-time high of $58,000. Other cryptotokens have also soared in value.

Speculation about an imminent rise in the rate of capital gains tax has led some business owners to accelerate their exit plans 

The follower notice provisions were introduced by FA 2014 and continue to be seen by the government as an important weapon in its fight against tax avoidance.

HMRC’s access to information on taxpayers’ assets, income, and gains, including overseas, is greater than ever due to international agreements