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Nudge, Nudge, Say No More………or should you?

What is the state of play with HMRC’s so called? “nudge letters” As HMRC gathers it’s thoughts on how to narrow the tax gap and recover monies used to assist 

Stamp Duty and Stamp Duty Reserve Tax (“SDRT”) changes – Finance Bill 2019/20

Introduction Finance Bill 2019/20 announced a couple of changes to the sleepy realm of stamp duty and SDRT. These are: An extension to the existing market value rule to include 

IR35: HMRC presses on with changes 

IR35: HMRC presses on with changes  Introduction HMRC has confirmed in Finance Bill 2019/20 that the IR35 changes scheduled to take effect from 6 April 2020 will happen as anticipated. 

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 

Tax abuse and insolvency – joint and several liability for tax debts

Tax abuse and insolvency – joint and several liability for tax debts Tax abuse and insolvency – what? Before you choke on your lunch, these new draft provisions forming part 

Transfer of Assets & Income Streams through Partnerships

Transfer of assets and income streams through partnerships Introduction As anyone with even the most fleeting interest in the UK tax system will know, the tax code is full of 

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 

Long in the Tooth? Another Discovery Assessment Found to be Stale

In HMRC v R Tooth [2019] EWCA Civ 826, the Court of Appeal has quashed a HMRC discovery assessment finding that it had gone “stale”. Raymond Tooth, the taxpayer, had 

Discovery Assessments & Staleness; Dealing with HMRC & Delays

Discovery Assessments and Staleness HMRC have the authority to open a discovery assessment into a taxpayer where HMRC discovers that: (a) Any income or chargeable gains, which should have been 

Derry Supreme Court Case – Technical Overview

Derry Supreme Court case – a technical overview Background – Derry Supreme Court case Earlier this week, the Supreme Court handed down its judgement in the Derry case. The decision 


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