Tag: HMRC
QROPS – A guide
QROPS – A BRIEF GUIDE 1. What is a QROPS? QROPS stands for “Qualifying Registered Overseas Pension Scheme. A QROPS is an overseas pension scheme which meets a number of criteria set out in legislation and regulations, the most important of which are that it: • is regulated as a […]
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Follower Notice penalties – the Corrado case
Follower Notice penalties – The Corrado Case The recently reported Corrado case has confirmed the validity of our approach to Follower Notice Penalties. In our previous blog post on the subject of Follower Notice Penalties, we noted that one of the most invidious (and potentially expensive) aspects of the Follower […]
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Loan relationships, connected companies and impairment losses
Loan relationships: connected companies and impairment losses We are frequently asked to advise on the loan relationships tax position where loans between connected companies have become irrecoverable. In most cases, there is a “tax nothing”; neither impairment losses nor release debits need to be brought into account in the respective […]
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Growth shares – the basics
Growth shares – the basics What are growth shares? Growth shares enable a new shareholder (whether an employee or not) to participate in the future growth of a company but do not confer an interest in the company’s existing assets. Share incentives structured in this way are generally far more […]
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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 […]
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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 […]
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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 […]
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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 […]
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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 […]
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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 […]
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