Discover

News & Insights

Read all our latest newsletters below or use the search facility to look for older items

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…

HMRC and the taxation of cryptoassets: DeFi, lending and staking

HMRC continues to update its guidance on the taxation of cryptoassets. The latest guidance addresses increasingly important issues associated with Decentralised Finance or “DeFi” including the tax implications arising when tokens are lent, borrowed and used as collateral and how any returns from these transactions are taxed. What are DeFi transactions? DeFi is an umbrella…

Clavis SPT – Tribunal decides in Portview that tax planning did not involve a deliberate or careless loss of tax

Just before Christmas, the First Tier Tribunal published its decision in Portview Fit-Out Limited; a case involving the Clavis Herald SPT planning, which was heard in July 2021. We posted an article in June last year that discussed the Tribunal decision in the Avonside Roofing case, which also involved the same planning. https://tridenttax.com/tribunal-decision-in-recent-clavis-herald-case-is-timely-reminder-that-hmrc-must-play-by-the-rules/. In that…

Cryptoassets and capital gains tax: a nudge from HMRC

As predicted some time ago, HMRC has now written to UK holders of cryptoassets to “nudge” them to check their capital gains tax position. The letter informs recipients that disposals of cryptoassets may give rise to capital gains tax liabilities. It explains that disposals of cryptoassets include: Selling them for sterling or other “fiat” currencies;…

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…