Kaye Adams v HMRC: Tribunal defeat broadcasts HMRC’s problems with IR35 Introduction As has been previously noted on the pages of this ‘blog, the vocabulary employed by HMRC to describe its pursuit of those whom it regards as unfairly dodging their fair share in tax is somewhat muscular. For instance, 
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Corporation Tax, HMRC & Late Filling Penalties – Introduction Corporation tax is due on the profits arising to UK limited companies and foreign companies with UK branches or offices. It is also due on trading profit, investment income and gains arising to clubs, cooperatives and other unincorporated associations such as 
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Information notices and the long reach of the tax man The Court of Appeal has decided in HMRC’s favour in an important decision about the department’s powers. The decision concerned HMRC’s ability to issue Schedule 36 information notices outside the UK. Such information notices are formal requests for information under 
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HMRC & Offshore Tax Penalties – The Facts Introduction According to Government figures, HMRC have raised over 32.9 billion from tackling offshore tax evasion and avoidance since 2010. The Requirement to Correct and associated Worldwide Disclosure Facility encouraged over 18,000 individuals to come forward by the 30 September 2018 deadline 
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What is a consortium company? A consortium is a group of companies that collectively holds a 75% minimum holding of a company between them, with the beneficial ownership being held by at least two different members. Therefore, a company can still be held by a consortium even if it has 
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Brexit + EU VAT Claims… The Need for Speed Tax is, of course, one of those areas, for which Brexit (in whatever form it takes) could have a significant impact. Indeed, we have recently produced a Brexit and UK taxation white paper outlining our view on the future of tax 
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IR35 & THE PRIVATE SECTOR It has been announced that the IR35 provisions relating to the public sector will be introduced into the private sector. The proposal is subject to consultation and the precise details are unclear, however, it might be useful to look at the public sector provisions to 
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HMRC Put a Spotlight on Phoenixing HMRC have published their new spotlight (47) expressing their discontent with schemes that seek to bypass the targeted anti-avoidance legislation commonly referred to as the ‘phoenixing provisions’. Those who have participated in such schemes should be cautious of challenge by HMRC, particularly in light 
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When it comes to R&D Tax Relief, software development is one area which has historically been challenging for both companies and advisers. Identifying whether a project qualified for relief could be difficult. Whilst it is easy sometimes to overlook “the other side of the fence”, these types of claims also 
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‘taxing statutes draw their life-blood from real world transactions with real world economic effects’ In 1936, Lord Tomlin made the (now) infamous statement which gave tax payers a decisive advantage over HMRC. In effect, this was an approval for tax professionals to exercise their ingenuity in the pursuance of a 
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