Category: News

The establishment of the Joint Chiefs of Global Tax Enforcement (or the J5 for short) in 2018 brought together tax enforcement authorities from the UK, Australia, Canada, the US and the Netherlands.  Its objective remains the tackling of serious international tax fraud. HMRC, together with its partners, has been investigating Euro Pacific Bank for over two…

The anonymised case of A taxpayer v Revenue and Customs[2022] UKFTT 133 (TC) provides a useful insight into HMRC’s approach on the conditions to be met for days spent in the UK to be ignored for the purposes of the Statutory Residence test on the grounds of exceptional circumstances. An individual who lived in Dublin, having…

In our Article in October 2021, we discussed some of the key features of single premium offshore life assurance bonds held by individuals and trusts. In this Article our focus turns to the tax pitfalls that may be encountered with offshore bonds and how they can be avoided. Personalised Portfolio Bonds One of the key…

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…

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 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…

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…

As predicted some time ago, HMRC has now written to UK holders of cryptoassets to “nudge” them to check their capital gains tax position. The letter informs recipients that disposals of cryptoassets may give rise to capital gains tax liabilities. It explains that disposals of cryptoassets include: Selling them for sterling or other “fiat” currencies;…

We were recently approached by a firm of accountants in the Midlands to assist with settling a long running dispute with HMRC. The fact pattern was simple, but nonetheless interesting.  A Bermudan resident company had been established in 1997 (with corporate directors) to hold UK rental property.  The shareholders of the company were also non-UK…

Ryan Conlon and Richard Wynne of Trident Tax had their recent Breakfast Tax Club presentation on “Taxation of UK residential property: Major changes & current opportunities” recorded by London Property – Home of Super Prime. Please visit the following link: https://lnkd.in/exsmGZXn where you’ll be able to watch the full presentation. If you would like to discuss any…