Domicile and The New Deemed Domicile Rules, HMRC Guidance & Notes The concept of domicile dates back to the Roman Empire and is generally described as a person’s permanent home. Although often referred to in a tax context, domicile is much broader and is rooted in private international law, which 
Read more
HMRC Enquires, Discovery Assessments & Closure Notices HMRC enquiries – background Each year, HMRC undertake checks to validate the information submitted on the more than 10 million self-assessment tax returns it receives. HMRC may select a random selection of returns for enquiry; however, HMRC have the right to open an 
Read more
Judicial Review and tax Introduction – Judicial review and tax The 2019 Loan Charge Action Group has launched a judicial review against HMRC in relation to the 2019 Loan Charge. In recent years, the courts have seen a sharp increase in judicial review against HMRC. In light of this, I 
Read more
HMRC vs D Higgins; Off Plan Purchases & Principle Private Residence Relief (PRR) Exemption… The recent decision in the case of HMRC v Desmond Higgins [2018] UKUT 280 (TCC) confirms that Private Residence Relief (PRR) in relation to gains made on the sale of a house, originally purchased off-plan, does 
Read more
Find & Follow ETC Tax



Submit an Enquiry