HMRC investigations into companies which used the “Clavis / Herald SPT” tax avoidance scheme Around August 2016, HMRC made the decision to transfer responsibility for all enquiries into the use of the Special Purpose Trust (“SPT”) tax avoidance scheme promoted by Clavis Solutions Limited (“Clavis”) which was partly implemented by a Jersey fiduciary company, Herald…
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Landmark decision in Rangers EBT case
The Supreme Court has ruled unanimously in favour of HMRC in the long running legal battle with what was the Rangers Football Club (“RFC”) prior to 2012. Some of the most important consequences of the decision for companies which have used EBTs as part of their remuneration arrangements for employees and directors will be that;…
Tax forecast post-General Election
Following the June election and the recent Queen’s Speech the outlook from a tax perspective remains very unclear.
CRS impact on offshore bank accounts & Requirement to Correct
In this short article, we discuss the impact of CRS tax reporting on the use of offshore bank accounts, recent changes and how we help our clients to stay compliant and on the right side of the law. A recent survey for the Financial Times by Wealth-X has found that UK wealth managers are quietly…
Did you know?
The House of Commons Library has published a paper called “Tax Avoidance: recent developments” which considers the issue of tax avoidance in the UK and what is being done to combat it.
Uncertainty for non-doms as tax changes are postponed
In a surprise move yesterday, the UK government announced that most of the tax changes announced in this year’s Finance Bill published on 20 March will now be postponed.
Revaluations for ATED
When the Annual Tax on Enveloped Dwellings (“ATED”) was introduced in April 2013, owners of ATED properties had to obtain a valuation of the property as at 1 April 2012, with revaluations taking place every five years. READ MORE
Budget 2017
Phillip Hammond’s first Budget contained few surprises and, aside from the NIC increase for the self-employed, not much of real significance in tax terms. We don’t propose to comment further on the planned reforms to non-dom taxation, all of which, importantly, the Budget statement confirmed will take effect from 6 April.
Tax Disputes & Risk Management conference this month
Trident Tax’s Alan Kennedy will be delivering a presentation on ‘The Current Landscape and HMRC Approach to EBTs and EFRBS’ at the Pump Court Tax Chambers on 21 March. FULL DETAILS
Loans and tainting protected trusts
Key points Existing offshore settlor interested trusts will be “protected” under new deemed dom rules But protection will be lost if further value is settled into trust Non-commercial loans owed by trusts may jeapordise protection HMRC has agreed a transitional period for changing loan arrangements The new legislation that introduces a deemed domicile status for…