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EU Law & UK Tax – A ‘High Level’ Analysis Introduction This note is a ‘high level’ analysis of the impact of EU law on the UK tax system and 
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Profit Fragmentation Rules Introduction – Profit Fragmentation Rules This has been billed as the new Diverted Profits Tax (“DPT”) for individuals, partners and SMEs. As such, covering the gaps in 
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EU tax avoidance directive – DAC6 – HMRC, Hallmarks, CRS & MDR Background Both the Panama & Paradise Papers have acted as a shot in the arm for those calling 
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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 
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Tracks & Tax, How Bob Geldof’s Flop Album ‘How to Compose Popular Songs That Will Sell’ from 2011 might result in a hit… From HMRC. Over the course of more 
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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 
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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 
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IHT and DOTAS HMRC recently introduced a new “hallmark” to the Disclosure of Tax Avoidance Schemes (DoTAS) regime with a view to closing the inheritance tax avoidance gap. The scope 
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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. 
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Time is Running Out! Time is running out to make a disclosure of historic offshore tax non-compliance before a punitive new regime of tax penalties is introduced. The Requirement to 
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