Some good news for taxpayers

Posted at 8:00 am on July 4, 2017 by Duncan Webster

In the past few weeks, the Courts have provided a fillip of good news for taxpayers who have claimed deductions and feel frustrated with their engagement with HMRC. Many taxpayers in matters that HMRC treats as suspected avoidance find HMRC carrying out a very slow process with regards to the enquiry and dispute negotiation, that… Continue reading

Spring Budget 2017: Tax Issues

Posted at 4:53 pm on March 8, 2017 by Taxxa LLP

Spring Budget 2017: Tax issues Spring Budget 2017 was relatively uneventful from the tax point of view, compared with the 2016 Autumn Statement. As we are told that this will be the last Spring Budget, this is, perhaps, not altogether surprising. Personal Tax and NIC There were, however, the beginnings of an attack on the use of… Continue reading

Non-Reporting Funds and Rebasing

Posted at 3:35 pm on February 1, 2017 by John Kavanagh

Non-Reporting Funds and Rebasing As our previous blog posts outlined, there are substantial changes to the taxation of long-term resident UK non-domiciliaries which take effect from 6 April 2017. The announcement in March 2016 that non-domiciled individuals who will become deemed domiciled for income tax and CGT purposes on 6 April 2017 would be able to… Continue reading

Carried Interest – when it arises and how much is the UK gain?

Posted at 9:34 am on January 27, 2017 by John Kavanagh

Carried interest – when it arises and how much is the UK gain? Our previous blog article on the new rules for the taxation of carried interest looked at their general impact on investment managers, including the introduction of the concept of income-based carried interest (“IBCI”) and the rule that carried interest that is not… Continue reading

Dave Hartnett, Former HMRC Permanent Secretary, criticised for flouting taxpayer confidentiality

Posted at 4:38 pm on October 19, 2016 by John Kavanagh

The Supreme Court has today (19 October 2016) issued a judgement criticising the conduct of Dave Hartnett, the former Permanent Secretary in charge of Her Majesty’s Revenue and Customs (HMRC), for remarks he made about Patrick McKenna, founder of the Ingenious Media Group, in an interview in The Times in June 2012. “Scams for scumbags”… Continue reading

Non-dom changes: Rebasing, trusts and mixed funds

Posted at 9:45 am on October 3, 2016 by John Kavanagh

Non-dom changes: Rebasing, trusts and mixed funds The Government recently updated the consultation on the changes to the taxation of non-UK domiciled individuals. We commented on some of the proposals in a previous blog. Although draft legislation is still not forthcoming, there have been some clarifications of the proposed tax rules affecting non-UK domiciled UK… Continue reading

Sam Allardyce, HMRC and “corruption”

Posted at 2:42 pm on September 29, 2016 by John Kavanagh

Sam Allardyce, HMRC and “corruption” Sam Allardyce, HMRC and “corruption” During his fateful meeting with undercover reporters from the Telegraph, the England national football team’s erstwhile manager, Sam Allardyce, made some trenchant criticisms of HMRC, accusing them of being the “most corrupt business in our country”. While I am not at all convinced that “corruption”… Continue reading

Settlements with HMRC: A warning

Posted at 12:36 pm on August 22, 2016 by John Kavanagh

Settlements with HMRC: a warning Although there has been a great deal of litigation regarding tax avoidance arrangements in recent years, many cases have not yet reached the courts. HMRC is keen to settle those cases, preferably without litigation and collect the tax. In last year’s Autumn Statement, the Government announced a ‘settlement opportunity’ for taxpayers… Continue reading

Carried interest, co-invest and tax planning

Posted at 12:45 pm on August 9, 2016 by John Kavanagh

Carried interest, co-invest and tax planning The new rules affecting the compensation of investment managers have now come into full effect. The changes Broadly, these are as follows: Carried interest now falls into one of two categories; Income Based Carried Interest (“IBCI”) which is subject to income tax and NIC, and carried interest which is… Continue reading

People with Significant Control: Piercing the Corporate Veil

Posted at 10:01 am on July 13, 2016 by John Kavanagh

People with Significant Control: Piercing the Corporate Veil Since 6 April 2016, UK companies and limited liability partnerships (LLPs) and UK registered Societates Europaeae (SEs) (hereafter referred to collectively for simplicity as “UK corporates”) have been required to maintain a register listing “People with Significant Control” (PSCs) in relation to the UK corporate. Partnerships which… Continue reading

This site requires cookies to function properly. You may disable cookies in browser settings. I understand