In Development Securities plc and others v HMRC, the Upper Tribunal (UT) has overturned the prior discussion of the First-tier Tribunal (FTT) in favour of the taxpayer in an important tax residence case relating to Jersey incorporated companies. ... - Continue reading
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
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
HMRC loses case against tax planning arrangements ... - Continue reading
HMRC updates its compliance check notice and it is bad news for tax evaders ... - Continue reading
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
The UK has published a policy paper setting out the direction for HMRC’s updated strategy for offshore tax compliance, offshore tax compliance strategy: No Safe Havens 2019. In the document, published alongside the chancellor’s Spring Statement, HMRC said it will use hefty punishments for those who enable offshore tax avoidance…. – Continue reading
Rangers manager Steven Gerrard is taking legal action against his wealth manager following a crack down on tax avoidance schemes. The former Liverpool captain is among hundreds of investors who have launched a £100m lawsuit against HSBC’s private banking division, claiming it defrauded them, The Times has reported. Composer Lord… – Continue reading
Britain’s parliamentary upper house has requested the current investigation limit set out in the Draft Finance Bill 2018 be scrapped. The House of Lords’ request to HMRC would, if passed, remove the 12-year offshore investigation limit from the Draft Finance Bill 2018 – a proposal that has seen an outcry… – Continue reading
Changes to Britain’s centuries-old trust regime are looming as HMRC is concerned that trusts are letting some families pay less inheritance tax than those who do not pay accountants to set up the complex arrangements. To look at if the law should be changed, HMRC has published wide-ranging research of… – Continue reading
A range of measures designed to crackdown on tax avoidance and evasion with a view to raise £2bn over the next five years have been announced by the government. HMRC will be made a preferred creditor in insolvencies, Chancellor Philip Hammond announced today. The government will end the practice of… – Continue reading
Caerphilly-based credit referencing company Creditsafe has paid Her Majesty’s Revenue and Customs almost £1 million after it was served with a ‘Diverted Profits Tax’ charge. Registered as Creditsafe Business Solutions, the company, based at Caerphilly Business Park, sells business data for credit check purposes and other uses. According to full… – Continue reading
HM Revenue and Customs is increasingly targeting estates it believes have undervalued residential property to avoid Inheritance Tax bills, according to an accountancy firm. HMRC investigated 5,400 estates for underpayment of inheritance tax (IHT) last year. This is up 5% from 5,100 in the 2016/17 tax year. One in four… – Continue reading
The British High Commission has advised British citizens to report and pay their tax on foreign income and assets. In a media release, the Commission said as part of the British Government’s “Requirement to Correct” legislation UK taxpayers must make sure that all their foreign income and assets, where there… – Continue reading
When it comes to fulfilling your tax and National Insurance (NI) obligations, compliance is everything. HM Revenue & Customs (HMRC) has recently highlighted a new area of concern for UK taxpayers, urging those who haven’t already done so to declare any foreign income or profits on offshore assets. Taxpayers have… – Continue reading
The HMRC published an official guidance yesterday on engaging with umbrella companies in the UK. The guidance provides advice and spotlights umbrella companies that effectively operate tax avoidance schemes. “Most employment agencies and umbrella companies operate within the tax rules. However, some umbrella companies and agencies promote arrangements that claim… – Continue reading
KARACHI: The Federal Board of Revenue (FBR) has served notices to around 400 residents of the port city owning properties in the UK, asking to clarify if they availed the recently floated amnesty scheme or not, sources said on Friday. “A tax department issued around 300-400 notices to Karachiites for… – Continue reading
ISLAMABAD: The people belonging to Karachi, Lahore and Islamabad are on top on account of receiving 75 percent tax notices from the Federal Board of Revenue (FBR) for owning expansive properties in UK out of total 600-700 properties. This information has been shared by the UK tax authorities in a… – Continue reading
UK taxpayers who receive any foreign income or profits from offshore assets have been urged to contact HMRC and disclose this income before 30th September 2018 to avoid being hit by higher penalties. David Redfern, tax preparation specialist and director of DSR Tax Claims, warned those affected to contact HMRC… – Continue reading
HM Revenue and Customs (HMRC) is urging UK taxpayers to come forward and declare any foreign income or profits on offshore assets before 30 September to avoid higher tax penalties New legislation called “Requirement to Correct’ requires UK taxpayers to notify HMRC about any offshore tax liabilities relating to UK… – Continue reading
The British tax man is asking foreign governments to chase down expats working overseas who have failed to pay the right amount of tax. Almost £6 million was raised for HM Revenue & Customs by foreign tax authorities in 2017. This was triple the amount raised from British expats in… – Continue reading
The UK does still have one significant disadvantage namely the 20% withholding tax imposed by UK domestic law on “yearly interest” that arises in the UK is paid to persons whose “usual place of abode” is outside the UK. The UK is normally regarded as an attractive location for the… – Continue reading
A vote by the UK parliament to insist that Britain’s Overseas Territories introduce publicly available beneficial ownership registers by December 31, 2020, has sparked anger and dismay within these autonomous, mainly small island, jurisdictions. An amendment to a UK Sanctions and Anti-Money Laundering Bill requires the British government to impose… – Continue reading
HMRC has formed an alliance with tax enforcement bodies in 4 countries to share intelligence and expertise in the battle against international tax crime. The UK has joined forces with Canada, the Netherlands, the United States and Australia to launch the Joint Chiefs of Global Tax Enforcement (J5) – a… – Continue reading
Most of the 3.2m EU citizens in the UK will be granted permission to stay after Brexit in “a matter of days” following simple data checks, the Home Office says. Information held by the tax or benefit authorities will be enough to confirm residence – and eligibility for the new… – Continue reading
HNWs need to be on top of their tax or face the Revenue’s ‘death ray’, writes Danny Bentley-White Bad news: the number of tax evasion cases identified by HMRC for the 2017/18 year was 3,809, an 18 per cent rise on 3,216 in 2016/17. These aren’t your ‘cash = No… – Continue reading
A recent proposal to amend HMRC rules for offshore is about to make tax investigations even more onerous, writes Colin Senez UK tax is complicated and convoluted and in certain circumstances can be tortuous. If you then add offshore taxation to the equation then the position can be even more… – Continue reading
According to figures released earlier this year, SMEs are in fact paying more corporation tax than larger more complex organisations. Specifically, the rate paid by SMEs in 2016 was 21.7%, while it was 20% for businesses with a turnover of £1billion. The research was conducted by accountancy firm Moore Stephens,… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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:… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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,… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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’… – Continue reading
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… – Continue reading
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… – Continue reading
