On 11 April, in a surprising announcement, HMRC published terms under which it is prepared (for a short period) to settle enquiries into tax avoidance schemes which used a particular type of trust, a Remuneration Trust or RT (“the RT Settlement Opportunity”). The announcement was surprising in the sense that there is already a Settlement…
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Year: 2021
No privacy for land or property owners?
Legislation for a new register for overseas entities with UK land or property and their beneficial owners was passed by Parliament on 14 March 2022. It will have huge implications for anybody managing an overseas entity that owns UK property or wants to buy or sell UK property. In turn, it will create complications for…
HMRC and the taxation of cryptoassets: DeFi, lending and staking
HMRC continues to update its guidance on the taxation of cryptoassets. The latest guidance addresses increasingly important issues associated with Decentralised Finance or “DeFi” including the tax implications arising when tokens are lent, borrowed and used as collateral and how any returns from these transactions are taxed. What are DeFi transactions? DeFi is an umbrella…
Clavis SPT – Tribunal decides in Portview that tax planning did not involve a deliberate or careless loss of tax
Just before Christmas, the First Tier Tribunal published its decision in Portview Fit-Out Limited; a case involving the Clavis Herald SPT planning, which was heard in July 2021. We posted an article in June last year that discussed the Tribunal decision in the Avonside Roofing case, which also involved the same planning. https://tridenttax.com/tribunal-decision-in-recent-clavis-herald-case-is-timely-reminder-that-hmrc-must-play-by-the-rules/. In that…