Business Investment Relief Introduction – Business Investment Relief Business Investment Relief (BIR) was introduced to promote investment in the UK by enabling UK resident non-domiciled individuals to invest overseas income and gains into the UK, without paying any tax on remitting the income or gains.  Conditions For BIR to apply, 
Read more
Common Reporting Standard Common reporting standard – introduction The Common Reporting Standard (CRS) is an agreement between over 100 jurisdictions to facilitate a universal system of automatic information sharing. In particular, this relates to UK residents holding foreign investments and property or has a source of overseas income. The CRS 
Read more
Requirement to Correct Requirement to Correct – Introduction The Requirement to Correct(RTC) legislation was introduced in the Finance (No 2) Act 2017 to bring into account offshore tax evasion and non-compliance that relates to income, assets, activities or anything having an effect as if it were income, assets and activities. In 
Read more
Split Year Treatment  General Rules Under the Statutory Resident Test, an individual is either UK resident or non-UK resident for a full tax year. However, if during a tax year the individual either starts to live or work abroad or comes from abroad to live or work in the UK, 
Read more
Introduction – statutory residence test Residence has a huge bearing on the tax position of a person for UK purposes.  Taxpayers who are resident in the UK in a tax year are taxable on their worldwide income and capital gains arising in that year,  while taxpayers who are NOT resident in the UK in a 
Read more
January not only marks the start of the New Year but, for many people, a fresh start – a chance to make changes to their private and professional lives. However, for millions of people across the UK, it’s a time of stress as they make an annual attempt to finalise 
Read more
What was NC26? NC26 (New Clause 26) was a cross party amendment to the Finance Bill proposed by the Liberal Democrat MP, Sir Edward Davey MP. In short, it asked for a review of the Government’s highly controversial, and deeply pernicious, April 2019 Loan Charge (“loan charge”).  The amendment passed 
Read more
NEW YEAR DISHONOUR: A KNIGHTHOOD AND A PARLIAMENTARY DOUBLE RAP FOR “PERVERSE” HMRC January is the time of year when many of us set out our intentions for the 12 months to come. Of course, abiding by resolutions requires a certain resolve, an ability to withstand pressure to change tack 
Read more
It’s perhaps unsurprising that, given the sums in broadcast rights, sponsorship income and salaries, sport seems to have become more of a priority for HMRC in recent years. Of course, this is not necessarily an entirely new departure. The Revenue’s attempts to lay claim to some of the riches paid 
Read more
An Englishman’s home, so the saying goes, is his castle. Over the course of recent decades, though, many Englishmen and women acquired second or third homes which often became a handy source of extra income. Some were gained by inheritance, some former residences were retained as the owner moved up 
Read more