KEY POINTS The non-dom consultation was published on 30 September This will have a huge impact on non-domiciled individuals who have been resident in the UK for at least 15 of the last 20 years Individuals will need to consider the impact for income tax, capital gains tax and inheritance tax In the Summer Budget…
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Category: News
New addition to our team…
We are delighted to announce that Gary Clarkson will be joining our team very shortly. Gary has joined the team following a successful career at HMRC, the Big 4 firms and a major law firm.
Sideways loss relief settlement opportunity
What is this? The settlement opportunity covers situations where an individual has made an investment that has resulted in a loss computed in accordance with Generally Accepted Accounting Practice (GAAP) but HMRC dispute that there is a real economic loss. A case typically involves an individual acquiring an investment with very little opportunity for a…
Advance Payment Notices (APNs) are here to stay!
The High Court has heard a Judicial Review that was looking to challenge whether APNs are lawful. Taxpayers who had received APNs argued that the notices were unreasonable, breached natural justice and contravened the EU Convention on Human Rights. The Court dismissed these arguments and decided in favour of HMRC. How do APNs work? HMRC…
Summer budget – what does this mean for you?
KEY POINTS • From April 2017, non-doms will be deemed UK domiciled for all tax purposes after 15 years of UK residence • The Corporation Tax rate is reducing, but shareholders will lose the 10% dividend tax credit • Offshore structures holding UK residential property will no longer prevent inheritance tax being charged on the…
Automatic exchange of information and closure of LDF
As we enter the final six months of 2015 we do so in the knowledge that tax authorities throughout the world remain under continued pressure to increase tax receipts and to that end their focus is aided by a number of national and international agreements which will see the automatic exchange of financial information between…
FA 2015 – A sting in the tail for Entrepreneurs Relief
KEY CHANGES FROM 18 MARCH 2015 Share disposals are no longer subject to the “look through” rule that previously applied to a corporate shareholding of 10% or more in a joint venture company (the “JVCo rule”). A new rule treats the activities of a company as the member of a partnership as not being trading…
CGT for non-UK residents
KEY POINTS From April 2015 HMRC will implement new Capital Gains Tax legislation on UK residential property non-UK residents For Companies ATED-related gains will take precedence over the new CGT rules PPR relief for non-UK resident individuals will be restricted from April 2015; The restrictions may also affect UK resident individuals disposing of a property…
Autumn Statement – Winter of discontent?
Key points SDLT & ATED rates increase – what now for non-doms? Principal Private Residence Relief rules tightened for non-residents Remittance Basis Charge – charges increase and a minimum period may be introduced The Google Tax – is it really just for multinationals? It was difficult to find any pre-Christmas cheer in the Chancellor’s statement and…
EBT and EFRBS Voluntary Settlements
Key Points Voluntary settlement should not be automatically ruled out Settlement terms can often be advantageous Advance Payment Notices mean cashflow benefit may cease in any event Each case is different and client objectives are paramount We have been dealing with a number of voluntary settlements of EBT and EFRBS arrangements with HMRC for clients…