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Anti-avoidance

‘Beating’ a path offshore?

Lockdown has seemingly given people a lot of time to think about their financial and tax plans.   Despite the relatively good weather we have had for most of our 

EU Law & UK Tax

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 

What is a Remittance?

What is a remittance? Non-UK domiciled individuals have the ability to claim the remittance basis which means that their overseas income or gains are not subject to UK tax if 

Digital Services Tax

Digital Services Tax Introduction It was back in Autumn Budget 2018 that ex-chancellor Phillip Hammond announced that the UK would take unilateral action to introduce a Digital Services Tax. With 

Profit Fragmentation Rules

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 

EU Tax Avoidance Directive – DAC6

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 

Luxembourg is first EU country to impose specific reporting requirements in relation to EU blacklisted jurisdictions.

Luxembourg is the first country to officially introduce reporting requirements for Luxembourg companies who transact with jurisdictions designated by the European Union as ‘non-cooperative’ for tax purposes. The measures, which 

Tax News; HMRC is Targeting Expats Living Abroad

Is HMRC targeting expats? According to The Telegraph, HMRC made 1,006 requests to foreign revenue authorities in 2017 for assistance with the recovery of tax debt. The figures, obtained under 

Related Party Transactions – Transfer Pricing Disclosure and Documentation

What is transfer pricing? Transfer pricing is one of the most important issues in international tax. Transfer pricing is the general term for the pricing of cross‐border, intra‐firm transactions between 

Tax Avoidance: Who’s Next on the Ducking Stool?

Tax avoidance – Caveat I will start with an International Consortium of Journalists (“ICIJ”) style caveat that “there are legitimate uses for offshore companies and trusts. We do not intend 

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