News & Insights

There was nothing new in the Autumn Statement that had an impact on Family Investment Companies (“FICs”). However, now the corporation tax rate increase in April is fixed, it is worth considering the effects this has on the investment return in a FIC. Dividends There are two significant points here. Firstly, the rise in the…

It was unsurprising that the recent arrest of eight people (including a tax agent) on suspicion of conspiring to submit over 100 fraudulent R&D relief claims, made the headlines.  Reports suggest that further arrests will follow while HMRC put out a statement confirming that, by acting quickly, it prevented public funds in the order of…

HMRC is issuing “nudge” letters to thousands of individuals whose submitted self-assessments tax returns included claims that at least some of the days spent in the UK were due to “exceptional circumstances” and should therefore be disregarded when determining their UK tax residence. UK tax residence is determined by the statutory residence test which permits…

HMRC will launch a new campaign in September targeting non-compliance by non-UK resident companies owning UK residential property. HMRC has extensive information at its disposal including the Land Registry enabling it to identify non-resident corporate owners of UK property that may not have met their UK tax obligations. HMRC will issue one of two letters:…

The establishment of the Joint Chiefs of Global Tax Enforcement (or the J5 for short) in 2018 brought together tax enforcement authorities from the UK, Australia, Canada, the US and the Netherlands.  Its objective remains the tackling of serious international tax fraud. HMRC, together with its partners, has been investigating Euro Pacific Bank for over two…

The anonymised case of A taxpayer v Revenue and Customs[2022] UKFTT 133 (TC) provides a useful insight into HMRC’s approach on the conditions to be met for days spent in the UK to be ignored for the purposes of the Statutory Residence test on the grounds of exceptional circumstances. An individual who lived in Dublin, having…

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…

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…

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 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…