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Category: News

Webinar: Domicile Record Keeping featuring Alan Kennedy!

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…

Autumn Statement and Family Investment Companies

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…

Tightening up on R&D relief – are stronger controls long overdue?

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 launch campaign to reject non-residence claims due to COVID lockdown

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…

Offshore property owners in HMRC sights

HMRC will launch a new campaign in September targeting non-compliance by non-UK resident companies owning UK residential property. HMRC has extensive information at its disposal including the Land Registry enabling it to identify non-resident corporate owners of UK property that may not have met their UK tax obligations. HMRC will issue one of two letters:…

HMRC promises “many more” tax investigations as it targets Euro Pacific Bank

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…

Offshore Bonds – Tax pitfalls

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…

HMRC offers new settlement terms for “Remuneration Trusts

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…

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…