Category: News

The Court of Appeal found for HMRC in the case of Centrica Overseas Holdings Ltd v HMRC, and this is a significant change to the previously understood treatment of certain expenses of a holding company in relation to disposals of subsidiaries. Centrica had incurred significant costs in taking advice on how to dispose of subsidiary…

The article written by one of our Senior Managers – Nigel Brown titled ‘Tax fraud – To prosecute or not to prosecute? That is the question’ has been featured in the February/March issue of HMRC Tax Investigations publication. In case you missed it when it was published on our website in December you can read…

A recent experience in an HMRC enquiry provided an introduction to the dark world of payroll fraud. This is not a situation where an employer falsifies PAYE returns to suppress employment income or hide benefits. Instead, the fraud we are looking at in this article has much more to do with organised crime and a…

Most readers of this article will be aware of the requirement of the Economic Crime (Transparency & Enforcement) Act 2022 for all overseas entities in England and Wales that have acquired an interest in UK real estate since 1 January 1999 to register details of beneficial ownership at Companies House by 31 January 2023. However,…

You’ve successfully grown and developed your business and may have reached the decision to either partially or fully exit. This could perhaps be because the next generation of your family are not interested in taking the business on and/or because you would like to realise value for the future and reap the rewards of your…

In 2016 HMRC’s Fraud Investigation Service (“FIS”) was formed bringing together both criminal and civil investigators, a world first for tax enforcement. Since then, more than £1 billion has been recovered from tax offenders and the proceeds of crime. HMRC has described that sum as being the equivalent to the cost of funding 20,000 NHS…

We are pleased to announce we have teamed up with the tax technology experts at Taxteq for a joint webinar on the importance of record-keeping for tax domicile, which will take place on November 30 at 4pm. On the agenda: domicile record keeping – preparing for enquiries and improving client relationships. Paul Aplin OBE will…

There was nothing new in the Autumn Statement that had an impact on Family Investment Companies (“FICs”). However, now the corporation tax rate increase in April is fixed, it is worth considering the effects this has on the investment return in a FIC. Dividends There are two significant points here. Firstly, the rise in the…

It was unsurprising that the recent arrest of eight people (including a tax agent) on suspicion of conspiring to submit over 100 fraudulent R&D relief claims, made the headlines.  Reports suggest that further arrests will follow while HMRC put out a statement confirming that, by acting quickly, it prevented public funds in the order of…

HMRC is issuing “nudge” letters to thousands of individuals whose submitted self-assessments tax returns included claims that at least some of the days spent in the UK were due to “exceptional circumstances” and should therefore be disregarded when determining their UK tax residence. UK tax residence is determined by the statutory residence test which permits…