About Thomas Slipanczewski

A tax adviser, Thomas joined ETC Tax in September 2018.

As noted in the COP9 acceptance article, the recipient of a COP9 letter must jump through a number of hoops to satisfactorily fall within the acceptance route and achieve immunity from prosecution. Anything else will amount to ‘non-cooperation’, whether or not in substance there is non-cooperation. In summary, non-cooperation will 
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Once a recipient of a COP9 letter has had chance to review the Code of Practice guide and reflect on previous conduct with an experienced tax adviser, if there is an acceptance of deliberate conduct, the best option will likely be to accept HMRC’s offer of entering into the contractual 
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Non-UK companies with UK rental profits are subject to corporation tax from 6 April 2020… Don’t get caught out There has been a special regime for all non-UK resident holders of UK property who let their properties. This is called the Non-Resident Landlord (“NRL”) scheme. The regime applied to individuals, 
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The highly anticipated loan charge review has been underwhelming for most, despite many living in hope, I think it reflects the general expectation from within the tax profession. We have previously set out a thorough analysis of the report and response [Loan Charge Review – Summary of Revised Payment Terms 
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HMRC & the Unsustainable Appeals – Freedom of Information Request Within the last two months, we have had considerable success in relation to a number of appeals we have made to the First-tier Tribunal, in relation to substantive challenges to HMRC decisions and penalties. In each case, HMRC had vigorously 
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Creative Industries Tax Relief – An Introduction for UK Firms The creative industries are a key part of the UK economy and the UK has sought to incentivise growth of these industries through a number of generous tax reliefs. The tax reliefs fall into the following categories: Film High-end tv 
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Stamp Duty Land Tax and the Purchase of Residential Property – The Facts, New Rates & Reliefs Stamp Duty Land Tax (SDLT) is payable on the purchase of a major interest in land or property in England and Northern Ireland (similar, yet different taxes apply in Wales and Scotland). SDLT 
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The Limit of Recovery and Enforceability: Income Tax, National Insurance and PAYE The myriad of rules relating to the recovery and enforceability of income tax, National Insurance and PAYE are lengthy, complex and substantively different. The Office for Tax Simplification has previously reported on the ‘creaking links’ between income tax 
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What is ‘Ordinary Share Capital’? – Types of Ordinary Shares vs. Preference Shares, Premiums & Characteristics. As the poet, William Blake, once said, “hindsight is a wonderful thing, but foresight is better”. This particularly rings true when devising a corporate exit strategy and ensuring the applicability of Entrepreneurs’ Relief (ER) 
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Discovery Assessments and Staleness HMRC have the authority to open a discovery assessment into a taxpayer where HMRC discovers that: (a) Any income or chargeable gains, which should have been assessed to tax, have not been assessed to tax; or, (b) An assessment to tax is or has not been 
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