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A Wolffe in sheep’s clothing I noted with some interest recently a more leftfield line of attack from HMRC on a tax planning scheme. The details of the scheme, called the ‘income trust’ and operated by a firm called Knight Wolffe, are largely irrelevant. It is how it was attacked 
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Introduction – Disguised remuneration & the April 2019 loan charge Of course, Se7en was a 1990’s shocker movie starring Brad Pitt, Morgan Freeman and Kevin Spacey (before he became US president, Frank Underwood). As you will recall, Kevin Spacey’s psychopathic  ‘John Doe’ character gruesomely disposed of each of his various 
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A person’s residence status – and specifically for the purposes of this article, whether they are UK tax resident – is incredibly important. It determines what taxes are payable and the quantum of such payments. With this in mind, one might be slightly surprised that it took until the 6 
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Business, as in so much of life, depends on developing and maintaining close, open and productive relationships. As friends in the media would have it, the key is “access” – the ability to observe and then relate the facts and individuals at the very heart of an issue of importance 
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These are, if you pardon the pun, taxing times for Theresa May’s Government. As well as her attempts to persuade Britain of the merits in tightening belts and being more convincing adopters of austerity measures, she has, of course, to steer the country through the turbulent and uncertain waters created 
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Stitch up? Lord Hodge, in last week’s highly anticipated judgement in the Rangers / Murray Holdings / RFC2012/Big Tax case, stated that the legislative code in relation to the taxation of earnings was not ‘a seamless garment but… a patchwork of provisions’. Of course, most interested parties will know that 
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Background The APN (including Follower Notices) legislation was introduced a couple of years ago to essentially prevent tax scheme users from dragging their feet on tax disputes. Initially, the rules were designed to avoid situations in which having secured judgement against one user of a particular scheme, others who had 
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Over the course of the last few months, the affairs of some of football’s biggest clubs and players have found themselves forced onto the back foot by one of the game’s most difficult opponents: the taxman. Once again, soccer’s finances have been scrutinised by those who believe that it’s not 
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Background The APN (including Follower Notices) legislation was introduced a couple of years ago to essentially prevent tax scheme users from dragging their feet on tax disputes. Initially, the rules were designed to avoid situations in which having secured judgement against one user of a particular scheme, others who had 
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Derry v HMRC The Court of Appeal handed down its judgement in the case of R on the application of Derry v HMRC on 20 June. It is a case that could be significant for individuals who have participated in marketed tax arrangements and have made claims to carry back 
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