2016

APNs on investors in failed Eclipse scheme

We understand that HMRC are set to issue payment demands for tax in excess of the amount that individuals invested in the various Eclipse Film Scheme partnerships in 2007.

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Investigations being undertaken by the Panama Papers taskforce

More than 30 companies and individuals are being investigated by the Panama Papers taskforce, the chancellor and the home secretary have announced. Read more
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UK AND OVERSEAS TAX ADVISORS LEGALLY OBLIGED TO WARN CLIENTS

Key points Advisors need to write to clients before 31 August 2017 HMRC’s ojective is to encourage taxpayers with undeclared offshore income/gains to come forward Advisors have a choice as to how they go about identifying clients to contact – …
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HMRC reviews criminal proceedings against some EBT users

HMRC has written to individuals who participated in EBT arrangements promoted by Clavis Herald Trust to note that enquiries will be taken over by its Fraud Investigation Service read more

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NEW OFFSHORE TAX PENALTIES TO ENFORCE CRS

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HMRC issues latest rules for non-UK doms and offshore trusts

KEY POINTS HMRC issued a consultation document on the reform of non-doms on 19 August The document introduces the concept of ‘deemed-domicile’ for income tax and capital gains tax There will be no ‘de-enveloping’ amnesty for residential properties owned by …
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EBT APN newsflash

HMRC has withdrawn certain Advance Payment Notices it issued when faced with a Judicial Review. The APNs were challenged by City law firm RPC and follows a similar case involving an EBT arrangement promoted by Montpellier in the Isle of …
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A new charge on pre-9 December 2010 loans from EBTs & EFRBS

KEY POINTS New measures designed to collect tax from old and new EBTs and EFRBS New tax charge on all outstanding loans to employees if not repaid or taxed by 5 April 2019 New disguised remuneration legislation to stop current …
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Taxation of company distributions & the new targeted anti-avoidance rule

Draft legislation for inclusion in Finance Bill 2016 was published by HMRC following December’s Autumn Statement to amend the existing anti-avoidance provisions for “transactions in securities” (“TiS”) and, to introduce a  new targeted anti-avoidance rule (“TAAR”) for certain distributions made …
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