Despite the policy intention behind the concept of protected trusts, it has now been discovered that a flaw in the legislation means that deemed domiciles will be taxable on…
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HMRC offers terms to settle Clavis Herald Trust tax planning
HMRC has written to a number of businesses that entered into tax planning arrangements promoted by Clavis Tax Solutions Limited that involved the creation of a Special Purpose Trust…
CGT on cryptocurrency transactions
Did you calculate the CGT on cryptocurrency transactions for your tax return correctly?…and what happens if you didn’t?
200% penalty for not notifying HMRC of your “transactions in land”
5th July 2016 was the commencement date for the very broad “transactions in land” legislation. Non-UK resident companies are within the scope of the legislation if they are dealing in or developing UK land, or if they have acquired UK land with the intention of realising a gain from its disposal or development. They are also…
UK Tax issues for trustees to look out for…
Trident Tax has been helping trustees outside the UK to identify possible UK tax issues ahead of the 30 September 2018 deadline for Requirement to Correct. The UK tax legislation will allow for swingeing “Failure to Correct” penalties to be charged if UK tax liabilities arising from non-UK assets are not disclosed by this date….
Italy: the new Monaco for HNWs?
For fairly obvious reasons, many high net worth individuals (HNW’s) with links to the UK choose not to be UK tax resident. This is becoming even more prevalent now, with some long term UK resident non-doms choosing to leave the UK to avoid becoming deemed UK tax domiciled under the “15 out of 20 years rule”…
Opportunity for radical improvement – let’s not miss it this time!
Tax risk: an opportunity for radical improvement – let’s not miss it this time! HM Revenue & Customs (HMRC) has just published a summary of responses to its consultation document (issued in September 2017) which asked for views on how the current approach to risk assessment for large businesses could be improved. We welcome many…
Trident Tax Launches New EBT/EFRBS Diagnostic Tool
Trident Tax is pleased to announce the launch today of a new electronic diagnostic tool and review service for professional advisers with individual employee and employer clients who have disputed liabilities under disguised remuneration schemes (EBT/EFRBS). The diagnostic tool and review service is provided free of charge on an anonymous basis and provides an indicative…
Protected trusts investing in the UK – the pitfalls!
Finance Act No.2 2017 creates a new category of “Protected trusts”, where the settlor is not actually UK domiciled, but becomes UK deemed domiciled under the changes in this Act.
HMRC issue guidance on cleansing mixed funds
No shortcuts, no best estimates, and a cliff edge. Finance Act No 2 2017 provided a “one-off” opportunity for non-UK domiciled individuals who have a cash mixed fund account to cleanse that account in the period from 6 April 2017 to 5 April 2019.