Category: United Kingdom

Extended tax liabilities for directors in insolvencies linked to tax avoidance

Draft legislation included in the Finance Bill 2019-2020 will potentially make directors and certain other individuals closely connected to a company jointly and severally liable for a company’s tax liabilities that arise from avoidance, evasion or repeated insolvency and non-payment of tax debts or tax-related penalties of the company. ... - Continue reading

US-born British citizen launches crowdfunding campaign to stop FATCA

A US-born British citizen has started a crowdfunding campaign to stop HMRC sharing her personal information with the US Internal Revenue Service (IRS) under the US Foreign Account Tax Compliance Act (FATCA). Law firm Mishcon de Reya has taken on the UK case for a client who alleges HMRC is… – Continue reading

British citizens born in America face having bank accounts frozen

Tens of thousands of British citizens born in the US but only lived there for a few months or years face having their bank accounts frozen as part of a crackdown by the US tax authorities.    The Internal Revenue Service (IRS) is ordering British banks to hand over the… – Continue reading

Tax from non-doms falls by £2bn as wealthy flee the UK

The number of wealthy residents who pay no UK tax on their offshore accounts has fallen to its lowest level ever, Treasury figures reveal. Last year, there were 78,300 non-domiciled taxpayers, or “non-doms”, in the UK compared with 98,500 in 2016-17. And the £9.5bn they paid to the taxman in… – Continue reading

UK: Non-Resident Capital Gains Tax on United Kingdom Real Estate: A New Regime

The legislation encompassing the new regime for taxing non-residents' gains on the United Kingdom (UK) commercial real estate came into effect on 6th April 2019. Her Majesty's Revenue and Customs (HMRC) has additionally published draft guidance on this recently introduced regime. This article briefly summarizes the new rules. ... - Continue reading

Gibraltar and UK Open Negotiations to Enter into a Double Tax Agreement

The Government of Gibraltar has said it is delighted to welcome Robert Jenrick, Exchequer Secretary to Her Majesty’s Treasury, to Gibraltar to announce that HMGoG and Her Majesty’s Government have opened negotiations to enter into a Double Tax Agreement. It is anticipated that with hard work on both sides a… – Continue reading

Tensions between the drive for transparency and the right to protection of privacy

Update on the UK government’s proposal to improve transparency with a new register of persons with significant control of companies which hold UK property. In our last article (https://hubbis.com/article/transparency-enhanced-in-the-uk) we looked at the UK government’s proposal to improve transparency with a new register of persons with significant control of companies… – Continue reading

Experts convene in the City of London to call out ‘pin stripe mafia enablers of tax abuse’

Researchers and campaigners from around the world have been presenting radical solutions on tackling tax abuse and financial crime at the Tax Justice Network’s annual conference held in the heart of London’s finance centre, on 2 – 3 July 2019. With over 200 attendees including prominent politicians, whistleblowers and economists,… – Continue reading

HMRC defeated as Jersey companies deemed not UK-resident

The UK’s Upper Tribunal has decided that three special purpose vehicles (SPVs) incorporated in Jersey as part of a tax planning arrangement were not tax resident in the UK for tax purposes, overturning a 2017 decision from the First-tier Tax Tribunal. Development Securities, a property and investment group based in… – Continue reading

Cyprus: The True Impact Of BEPS On International Business Structures

In the last decade, OECD officials have recommended measures to combat tax avoidance, culminating first in the BEPS (Base Erosion and Profit Shifting) initiative in 2015 and then the MLI (Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS) effective from July 2018 – yet have all their… – Continue reading

British overseas territories top corporate tax loophole index

Governments are stepping up efforts to recoup more tax from multinationals, with the European Commission forcing iPhone maker Apple to repay 13 billion euros after it used Ireland to cut its tax on European profits to almost zero. The Tax Justice Network, a group campaigning for transparency, said its study… – Continue reading

New ranking reveals UK’s role in breakdown of global corporate tax system

Decades of tax wars among the world’s richest countries are unravelling the century-old global corporate tax system, new research finds. Forty per cent of today’s cross-border direct investments reported by the IMF – $18 trillion in value – are being booked in just 10 countries that offer corporate tax rates… – Continue reading

UK – HMRC WINS TWO TAX AVOIDANCE CASES OVER USE OF OFFSHORE TRUSTS

The HMRC has successfully argued two cases in the First-tier Tribunal involving the use of offshore trusts to avoid tax and National Insurance Contributions (NICs). The case was brought against Hyrax Resourcing Limited and Curzon Capital Limited. The Tribunal decided in both cases that the disguised remuneration arrangements being promoted… – Continue reading