British lawmakers are shifting their focus towards the offshores and tax havens detailed in the Panama and Paradise papers, in order to improve tax collection, curb multinationals’ tax avoidance practices, and track the money flows of ill-gotten gains. Kristian Rouz — Members of Parliament (MPs) are set to investigate the...
Apple Europe Ltd, a wholly owned subsidiary of Apple Inc., said it expects to pay more tax in the UK and paid an extra GBP136m for prior years up to September 26, 2015, after an extensive audit by HM Revenue and Customs. In its end-of-year accounts made up to April...
The case of Development Securities (No. 9) Ltd and other v HMRC [2017] UKFTT 0565 is the latest in a line of cases concerning the UK corporate tax residence of offshore companies. The case once again highlights the difficulties in preserving an offshore company’s non-UK tax resident status, whilst giving...
Introduction As the government continues to grapple with a budget deficit and strained public finances, there remains considerable pressure on HMRC to crack-down not only on tax evasion, which is illegal, but tax avoidance, which HMRC refers to as “bending the rules of the tax system to gain a tax...
On 11 September 2017, His Honour Judge Colin Bishopp handed down his judgement in the case of The Commissioners for Her Majesty’s Revenue and Customs –v- (1) Root2tax Limited (2) Root3tax Limited (in liquidation) [2017] UKFTT 0696 (TC). The Root2 judgement concerned HMRC’s application to the First Tier Tax Tribunal...
Island tax expert Greg Jones has issued a warning saying he believes the UK taxman has ‘bulked up’ and is starting to ‘flex his muscles.’ Mr Jones, a director of KPMG at its offices in Athol Street, Douglas, has analysed the UK Budget in this special report for Business News:...
The UK government is planning to extend the time limit to 12 years for HM Revenue & Customs (HMRC) to investigate all offshore tax non-compliance, according to documents released as part of the Budget. A Treasury document entitled ‘Tackling tax avoidance, evasion and non-compliance’ states that the government will consult...
UK Offshore tax evaders face much higher penalties for non-compliance under new HM Revenue and Customs rules. The legislation requires those with undeclared offshore tax liabilities to disclose them to HMRC before the 30th of September next year. When the Right to Correct rules come into force, offenders can expect...
The difference between the tax due and that collected by the UK tax authority, HM Revenue and Customs (HMRC) – known as the “tax gap” – fell to a record low of six percent in the fiscal year 2015-16, according to official statistics released on October 26, 2017. HMRC pointed...
HMRC has warned convenience retailers to “play by the tax rules” or face the consequences as new stats show a disproportionate amount of tax evasion is committed by convenience stores. While accounting for less than 1% of businesses, convenience stores and newsagents now account more than 6% of all incidents...
Inquiry to centre on George Osborne’s 2013 rule change that allows resident multinationals to shift income offshore The EU is to launch an investigation into a British government scheme that may help multinational firms pay less tax, the Guardian has learned. Margrethe Vestager, the EU competition commissioner, will announce on...
HM Revenue and Customs, the UK tax authority, has welcomed a ruling in its favor against a contrived tax avoidance scheme involving an entity in Jersey and the Cayman Islands. HMRC says it expects that the decision will recover GBP325m in unpaid tax. The decision on the scheme, known as...
Kenneth Moyes, brother of Manchester United’s former manager David Moyes, has been disqualified as director for five years after the Insolvency Service found he withdrew cash from his company to avoid paying tax Moyes was the owner of Glasgow-based Professional Pre Season Tours, which was involved in arranging pre-season tours...
An estimated $3.5 billion in revenue from large corporates and multinationals is at risk to the economy, but through audit activity this will reduce to $2.5 billion, according to the Australian Taxation Office. On Wednesday the agency is releasing the first tranche of its long-awaited highly anticipated “tax gap” figures,...
The 30 September 2017 is an important date for HMRC and its “relentless” clampdown on global tax evasion. First, it marks the coming into force of the landmark corporate offence of failure to prevent tax evasion under Part 3 of the Criminal Finances Act 2017. Secondly, it is the commencement...
Solicitors providing tax planning services could face greater scrutiny from the Solicitors Regulatory Authority (SRA) and HMRC as government begins to clamp down on aggressive tax avoidance schemes The SRA has expressed its concerns that avoidance schemes previously deemed legitimate may no longer be accepted by HMRC. Solicitors and firms...
Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL...
A ruling from advertising watchdogs that carrying the HM Revenue & Customs on advertising materials is misleading leaves the way open for government departments to challenge firms over misleading consumers. The Advertising Standards Authority (ASA) investigated a web site and leaflet published by tax and wealth advisors Knight Wolffe after...
Changes to partnership taxation are to go ahead with draft legislation now published, effectively clarifying the tax treatment for partnerships to ensure that the principle of taxing the beneficiary of partnership profit applies and to prevent a double reporting burden on investment partnership This measure makes changes to the income...
HMRC is probing at least two Manchester United players over potential image rights tax dodging, as reported by the Daily Mail. The tax avoidance allegedly occurred under an agreement in the 2014-2015 season, where clubs could pay up to a fifth of their footballers’ total pay packages to ‘image rights’...
Wealth managers have only days to send clients warning letters about disclosing overseas assets to the taxman, or risk a £3,000 fine. Wealth managers, advisers and fund managers have until 31 August to send an HM Revenue & Customs (HMRC) approved letter to clients about holding assets abroad which warns...
The Supreme Court has recently ruled in favour of HM Revenue and Customs in a long-running dispute with Rangers FC over the use of employee benefit trusts (EBT) as a means of avoiding tax. The case, which was initially decided in favour of the Glasgow-based football club in two employment...
HMRC has continued to win the majority of its tax avoidance litigation cases this year, new figures published by the Revenue on Monday have shown Of the 26 cases where HMRC considered tax avoidance was involved in 2016/17, 22 were won by the Revenue, three were lost and one had...
The UK tax authority, HM Revenue and Customs (HMRC), has issued guidance for businesses on the preparation of country-by-country reports in the required format. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under Action 13 of the OECD’s base erosion and...
INTRODUCTION HMRC have successfully challenged the offshore residence of Jersey companies holding UK real estate. In the case of Development Securities, the First Tier Tribunal held that Jersey companies set up to hold UK real estate were resident in the UK for tax purposes. This case serves as a timely...
The UK tax authority, HM Revenue and Customs (HMRC), has warned taxpayers to avoid disguised remuneration schemes that attempt to recharacterize loan arrangements to avoid the 2019 loan charge on disguised remuneration. “HMRC is aware of schemes that claim to avoid the 2019 loan charge on disguised remuneration. These schemes...
Paying employees in gold bullions to avoid tax will not be permitted under the first use of the general anti-abuse rule (GAAR). The GAAR advisory panel stated that the use of gold as payments for employees is “abnormal and contrived” and “not a reasonable course of action”. “We can see...
HM Revenue and Customs (HMRC) has released guidance on a change to value-added tax rules to tax services used outside the EU by UK consumers. The changes, which were introduced in the Spring Budget 2017, will affect suppliers of mobile telecommunication services, private consumers, and non-business users who consume telecommunication...
THE BENEFITS OF NON-DOMICILE STATUS An individual who is resident but not domiciled in the UK does not pay tax on overseas income and gains, as long as they are kept outside the UK and are not used to provide benefits in the UK. This is called the remittance basis...
HM Revenue and Customs (HMRC) has collected more than £4bn through its controversial ‘pay now, dispute later’ accelerated payment notices rules, for people who have used a tax avoidance scheme. HMRC said that more than 75,000 accelerated payment notices (APNs) have been issued to people under enquiry for tax avoidance...
Andrew Howard, Ropes & Gray tax partner, discusses the UK’s new corporate criminal offence of failure to prevent tax evasion, which goes into effect in September 2017. Click here to view video. Transcript: The UK’s new corporate offence of failure to prevent facilitation of tax evasion is quite a mouthful,...
The Revenue received 24% more requests for assistance from overseas governments with probes into taxpayers from overseas jurisdictions last year A freedom of information (FOI) request from law firm Pinsent Masons found that a total of 2,015 requests had been made to HMRC last year, up from 1,619 in 2015....
‘Misleading media reports’ Ingenious Film has hit out at “misleading” press reports on its ongoing tax court case and criticised HM Revenue & Customs (HMRC) for painting its partnerships “as nothing more than tax avoidance vehicles”. The film production partnership firm has been in an ongoing court dispute with HM...
The amount of disputed tax relating to the transfer pricing of the U.K.’s largest businesses has risen 60 percent in the past year, according to law firm Pinsent Masons. Her Majesty’s Revenue and Customs, the U.K.’s tax authority, is reviewing as much as 3.8 billion pounds ($4.9 billion) of large...
The first set of ‘hidden’ financial data about Britons living abroad is set to be handed to the UK’s Revenue & Customs later today, as part of the global transparency drive that has been introduced via a series of information sharing agreements across the world’s financial centres. As a result,...
The deadline for submitting automatic exchange of information (AEOI) returns for the year ended 31 December 2016 is 31 May 2017 for financial institutions, and that this is the first year for common reporting standards (CRS) filing Returns should include reportable accounts for the financial accounts tax compliance act (FATCA),...
The Common Reporting Standard (the CRS) is, like FACTA (the Foreign Account Tax Compliance Act), an information exchange regime aimed at realising international tax transparency. Exchange of information under CRS is achieved by requiring certain bodies including banks and other “Financial Institutions”, to collect data and report some of it...
The U.K’s diverted profits tax was dubbed the ‘Google Tax’ even before its introduction in April 2015. Yet instead of netting foreign tech companies engaged in complex tax planning such as California-based Google Inc., only U.K. multinational companies outside the technology sector have issued warnings so far over the tax...
The Criminal Finance Act 2017 received Royal Assent on April 27, 2017, making its way onto the statute book before the halting of Parliamentary business ahead of this year’s general election. As well as giving enforcement agencies further powers to recover the proceeds of crime and tackle money laundering, the...
This article is the first of a series of articles that looks at tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors. An essential feature of...
A high percentage of UK executives are unaware of the impending introduction of new laws which could make a business’s failure to prevent tax evasion by its employees and agents a criminal offence, according to research by Pinsent Masons, the law firm behind Out-Law.com. In a YouGov poll of more...
Newcastle managing director Lee Charnley released after HMRC investigation Offices at St James’ Park and club training ground raided by tax authorities The offices of Newcastle United and West Ham United were raided on Wednesday morning and Chelsea confirmed they were asked to provide information as part of a wide-ranging...
Many of the data submissions made by early adopters over the next two months under the new common reporting standard (CRS) are likely to be rejected and returned for correction and resubmission, adding to compliance costs, according to predictions from Sovos, a global tax compliance solution provider The UK is...
HMRC is to renew and extend the scope of the double taxation treaty passport (DTTP) scheme, which will now be available to all UK borrowers who are required to withhold income tax at the basic rate on certain loan interest payments to overseas lenders from 6 April 2017 The DTTP...
HMRC has launched a new hotline for the public to report fraud and evasion, replacing the existing two separate tax evasion and customs hotlines with one, in a bid to streamline information gathering on tax fraud. Individuals can report all kinds of tax fraud and evasion on the new hotline,...
Dedicated technical experts from the UK’s HM Revenue & Customs (HMRC) will visit all English Premier League, Championship and Scottish Premier League clubs over a three year period and review all compliance risks including payments to players, the government has said. The statement was made in Treasury Minutes containing the...
HMRC has launched its Making Tax Digital for business pilot to test out its new reporting system, with a year to go before businesses with turnovers above the VAT threshold are required to switch to digital records and provide quarterly summary updates from April 2019 This month HMRC says it...
Google says it paid 36.4m (AUD59.8m) in UK corporation tax in the last financial year, as the internet firm’s operations in this country remain mired in controversy. The US company, which was revealed early last year to have done a 130m (AUD213.7m) deal with the taxman covering 10 years of...
HM Revenue and Customs (HMRC) is planning to make its Double Taxation Treaty Passport (DTTP) scheme available to all UK borrowers following a consultation on a legislative amendment. The DTTP scheme provides for Double Taxation Relief on UK loan interest payments made by a UK corporate borrower to overseas corporate...
The 2017 Finance Bill was published on Monday 20 March, introducing dozens of initiatives with a focus on improving and modernising the tax system The Treasury said the bill, which is over 700 pages in length, “continues the government’s crackdown on tax avoidance” and “improves the fairness of the tax...
