Tag: HMRC

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

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

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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long term tax strategy

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

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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De Silva

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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General Anti-Abuse Rule

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

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

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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apns

APNs, HMRC & The Courts – Guilty Until Proven Innocent?

Accelerated Payment Notices (APNS), Judicial Review and Interim Relief In over 32 years of working in tax, I find it difficult to think of any tax legislation that has been as bitterly contested, both in consultation and subsequently, as the Accelerated Payments provisions eventually enacted in the 2014 Finance Act. […]

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