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Achieving a successful outcome in a tax investigation: case study

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…

Breakfast Tax Club Recording – “Taxation of UK Residential Property: major changes and current opportunities”

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…

Offshore Bonds: A Beginner’s Guide

Single premium non-qualifying life assurance policies issued by non-UK life assurance companies “offshore bonds”, have been in existence since the late 1960’s and today their principal attractions remain the same as they have always been. If the rules on how investments can be made are followed correctly, significant tax benefits can be achieved over a…

How significant is the FTT’s recent decision in Marlborough DP Limited?

The FTT’s decision in favour of the taxpayer in the case of Marlborough DP Limited v The Commissioners for HMRC [2021] UKFTT0304 (TC), released on 1 September, goes against the grain of most of the judicial decisions over the course of the last few years in cases involving trust arrangements by close companies and their…

Reasonably required? – Tribunal reins in HMRC request for information

A First Tier Tribunal recently considered this in the case of Syngenta Holdings Ltd v HMRC, [2021] UKFTT 236, in relation to HMRC’s request for disclosure of a number of categories of information, include a request that “the emails to [five named individuals] for the period of two years leading up to the approval of…

The UK Real Estate Tax System Podcast

Alan Kennedy of Trident Tax recently recorded a podcast for the London Property Network, discussing UK real estate tax issues for overseas investors. You can listen to it here or through any of the usual podcast providers. If you would like to discuss any of the topics mentioned in the podcast then please contact us.

Business as usual: HMRC and Family Investment Companies

A family investment company (“FIC”) is a company established to help pass wealth to the next generation while enabling the founders to continue to exercise control over the assets. Business as usual In April 2019, HMRC established a dedicated team to review the use of FICs, to better understand the profile of those establishing them,…