Category: HMRC

EXCLUSIVE: HMRC tells retailers “play by the rules” or face the consequences

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

EU to investigate UK tax loophole for multinationals

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

Football tours operator banned over tax avoidance

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

ATO’s tax gap figures revealed: $2.5 billion missing from corporates, multinationals

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

Will the new corporate offence of failure to prevent tax evasion and enhanced international tax transparency change the landscape for tax investigations?

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

Interpreting double tax treaties in light of the BEPS multilateral instrument

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

Tax Avoidance Firm Loses ‘HMRC Approved’ Ad Challenge

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

Partnership tax rules overhaul by 2018

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

UK Issues Guidance On Preparing CbC Reports

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… – Continue reading

Jersey property companies lose tax residence case

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… – Continue reading

2017 changes to the taxation of non-domiciliaries – deemed domicile status, rebasing, cleansing mixed funds, business investment relief

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… – Continue reading

HMRC tops £4bn in tax avoidance scheme crackdown

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… – Continue reading

Thousands of British expats could face tax penalties for undeclared cash: report

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,… – Continue reading

31 May deadline for filing automatic exchange of information (AEOI) returns

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),… – Continue reading

The common reporting standard and charities: do you have filing requirements with HMRC?

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… – Continue reading

Why U.K. ‘Google Tax’ is Hitting British Plc

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… – Continue reading

Corporate Criminal Offence: Failure to Prevent Facilitation of Tax Evasion

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… – Continue reading

UK: The UK Company: A New Alternative For International Investors?

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… – Continue reading

Survey finds low levels of awareness of new ‘failure to prevent’ tax evasion offences

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 In a YouGov poll of more… – Continue reading

Newcastle United and West Ham raided in HMRC tax fraud investigation

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… – Continue reading

Early adoption of tax common reporting standard problematic

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… – Continue reading

HMRC to visit football clubs to review ‘image rights’ and other tax compliance

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… – Continue reading

UK To Expand Double Tax Treaty Passport Scheme

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… – Continue reading

Finance Bill confirms measures to crack down on tax avoidance

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… – Continue reading

HMRC guidance clarifies fit and proper persons test

It says anyone who has been involved in designing or overseeing tax-avoidance schemes using charities would be unlikely to pass the test People who have been involved in designing or overseeing schemes to avoid tax using charities are likely to be prevented from taking up senior roles in charities, according… – Continue reading

Offshore tax evasion: compliance and penalties – part 1

Sometimes it can be hard to keep up with the avalanche of government announcements on tax avoidance and evasion. In the first of a two part series, Jason Collins, a member of the CIOT’s management of taxes sub-committee and partner at Pinsent Mason, provides an overview of the rapidly changing… – Continue reading

Inheritance tax Residence Nil Rate Band: why it won’t benefit everyone

The new Residence Nil Rate Band will allow people to pass on property to their descendants tax free. But some people need to take action now or risk missing out. In April, a major change to inheritance tax (IHT) law comes into effect with the launch of the Residence Nil… – Continue reading

Mind the gap – HMRC’s crackdown on SME directors

Last Autumn, HMRC issued “Measuring Tax Gaps”, an annual report on the estimated UK tax gap. The tax gap being the shortfall in tax estimated by HMRC as being due in any one tax year from that which is eventually collected. In the accompanying press releases and in comments made… – Continue reading


HM Revenue and Customs’ failure to get tough with Britain’s richest individuals is undermining confidence in the whole tax system, MPs have warned. In a scathing report, the Commons Public Accounts Committee accused HMRC of creating the impression in its dealings with taxpayers there was “one rule for the rich… – Continue reading