The recently published Finance Bill 2017 No.2 contains the new rules for deemed domiciles.
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HMRC to open new facility for settling EBTs and similar tax schemes
The Supreme Court unanimously ruled in favour of HMRC in the Murray Holdings case (Glasgow Rangers).
When does failed tax planning become criminal?
A senior HMRC official has often been quoted as suggesting that “the difference between avoidance and evasion is the thickness of a prison wall”.
31 August 2017 – A key date for the diary
A reminder to all tax advisors or financial institutions, that they must write to their clients on or before 31 August 2017 to advise that HMRC will shortly start receiving financial information regarding UK residents from overseas jurisdictions via the Common Reporting Standard.
Recent domicile case goes in HMRC’s favour (unsurprisingly)
A recent First Tier Tribunal (Henderson [2017] UKFTT 0556 (TC)) has dismissed an appeal from four appellants that they were non-UK domiciled.
First ever decision of the GAAR panel supports HMRC
On 3 August the first ever decision of HMRC’s General Anti-Abuse Rule (GAAR) panel was published. The panel decided in favour of HMRC in relation to arrangements which were designed to reward two employee/shareholders using gold, involving an Employee Benefit Trust (EBT), whilst avoiding PAYE/Income Tax, NIC and Corporation Tax (CT). The implications for the…
HMRC FOCUS ON DOMICILE ENQUIRIES
As many non-doms become deemed domiciled in the UK, HMRC are taking the opportunity to challenge their historic domicile status. A notable increase in domicile enquiries from HMRC appears to confirm our understanding that HMRC is dedicating specific resources to this area. This may be driven by a perception at HMRC that there is one…
HMRC tax investigations – the yield dichotomy?
A recent report has concluded that yields against expenditure on HMRC investigatory staff have fallen by up to 17% in the last tax year.
Updated deemed domicile legislation published
The Treasury has published updated draft legislation for the planned changes to the taxation of non-UK domiciles. The big news is that the changes will be effective from 6 April 2017 and will not be rolled forward to 2018; bad news for anybody hoping to delay the effects or who wanted a second chance to…
New draft tax rules from the EU Commission
which will mean financial advisors and other professionals face heavy fines if they are found to have helped individuals or companies cut their tax bills by using “aggressive tax planning schemes”.