The myth of the long-term tax strategy
The myth of the long term tax strategy I am often asked by accountants to help advise their clients on long-term tax strategy. I’ll be honest – this gives me a problem. Mythical beast And it’s because the long-term tax strategy is something of a mythical beast – or at […]Read More
CEST, MOO and Status Anxiety
Status Anxiety A few years ago, I read a book with this title by the philosopher Alain de Botton, wherein he described status anxiety as the constant fear of being perceived by society as unsuccessful – a very 21st century and decidedly first world problem. In the tax and employment […]Read More
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 More
The Post-Incorporation Directors Loan Account – A Potential IHT problem?
THE POST-INCORPORATION DIRECTORS LOAN ACCOUNT – A POTENTIAL IHT PROBLEM? The Incorporation Boom In the late 2000s and early 2010s, incorporation was for many sole traders and partnerships running businesses, something of a “no-brainer”. There were numerous reasons for this. Firstly, from the 2008/9 tax year onwards, capital gains tax […]Read More
Non-resident CGT on UK Property – the right measure at the wrong time?
Non-resident CGT on UK Property – the right measure at the wrong time? In over 30 years as a tax adviser, I find it difficult to think of a more fundamental change of principle in the UK tax system than the imposition of UK tax on disposals by non-residents of […]Read More
Hopes dashed for appellants in De Silva case
Hopes dashed for appellants in De Silva case The Supreme Court yesterday (15 November) handed down its judgement in the case of R (on the application of De Silva and another) v Commissioners for Her Majesty’s Revenue and Customs. The appellants in the De Silva case were limited partners in […]Read More
The 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 More
Derry v HMRC: Failure to make correct enquiries prevents HMRC from collecting tax in tax avoidance case
Derry v HMRC The Court of Appeal handed down its judgement in the case of R on the application of Derry v HMRC on 20 June. It is a case that could be significant for individuals who have participated in marketed tax arrangements and have made claims to carry back […]Read More
Offshore 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 More
Follower 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 More