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Using a small self-administered pension scheme (SSAS) to own business premises
USING A SMALL SELF-ADMINISTERED PENSION SCHEME (SSAS) TO OWN BUSINESS PREMISES What is a SSAS? A SSAS is an employer-sponsored pension scheme (established as a trust) with fewer than 12 members, usually restricted to senior employees or directors of a limited company. The members of the scheme will also be […]
Read MoreThe General Anti-Abuse Rule (GAAR): What’s the point?
The General Anti-Abuse Rule (“GAAR”) The General Anti-Abuse Rule (“GAAR”) first came into effect in July 2013 on the passing into law of that year’s Finance Act, introduced by George Osborne, the then Chancellor in the Coalition Government. Yet it was 4 years later when the GAAR panel issued its […]
Read MoreOffshore evasion: the Common Reporting Standard (“CRS”), the Requirement to Correct and HMRC
OFFSHORE EVASION: The Common Reporting Standard Our many readers who work in the offshore financial services sector will be all too aware of the attack on offshore evasion that lies behind the Common Reporting Standard (“CRS”). The CRS is a global initiative originating from the Organisation for Economic Co-operation and […]
Read MoreFollower Notice penalties – a guide
Follower Notice penalties – a guide Numerous cases involving marketed tax avoidance arrangements are still making their way through the courts and tribunals. Where HMRC has won those cases and all avenues of appeal on the part of the affected taxpayers have either been exhausted or abandoned, it has begun […]
Read MoreCarried Interest – when it arises and how much is the UK gain?
Carried interest – when it arises and how much is the UK gain? Our previous blog article on the new rules for the taxation of carried interest looked at their general impact on investment managers, including the introduction of the concept of income-based carried interest (“IBCI”) and the rule that […]
Read MoreSettlements 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 […]
Read MoreCarried 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, […]
Read MoreFollower 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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