Author: John Kavanagh
Non-dom changes: Rebasing, trusts and mixed funds
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 […]
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Sam Allardyce, HMRC and “corruption”
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 […]
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Settlements with HMRC: A warning
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 […]
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Carried interest, co-invest and tax planning
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, […]
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People with Significant Control: Piercing the Corporate Veil
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 […]
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Follower notice penalty assessment? What can be done?
Follower notice penalty assessment? What can be done? One of the most invidious aspects of the follower notice regime is the way that a follower notice penalty of up to 50% of the denied tax advantage is charged if the recipient of a follower notice fails to take “corrective action” […]
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"Fair share of tax" – Does this mean anything to HMRC?
“Fair share of tax” – Does this mean anything at all to HMRC? If ever there was a topic nearly as hot as immigration in the minds of the general public, it is the question of who does and who does not pay their fair share of tax. What actually constitutes […]
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Brexit: UK tax implications
Brexit: UK tax implications As the newspaper column inches and TV and radio schedules fill with claim and counterclaim about the benefits and disadvantages of leaving or remaining in the EU, Taxxa takes a look at Brexit’s UK tax implications. VAT VAT is the most European of UK taxes. UK […]
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Eclipse 35 – the final death knell
Eclipse 35 – the final death knell The members of the Eclipse 35 partnership heard on 14 April that the Supreme Court had refused their request for leave to appeal against the Court of Appeal’s decision that their activities did not amount to trading. Having lost at both the First […]
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Some tax avoidance schemes do work
Some tax avoidance schemes do work… “Some tax avoidance schemes do work. They avoid tax by adopting a legitimate, justifiable and commercially sensible structure to achieve a result which could be achieved by other legitimate and justifiable means. Where, however, that structure is artificial or has no purpose other than […]
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