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, 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, 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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Dave Hartnett

Dave Hartnett, Former HMRC Permanent Secretary, criticised for flouting taxpayer confidentiality

The Supreme Court has today (19 October 2016) issued a judgement criticising the conduct of Dave Hartnett, the former Permanent Secretary in charge of Her Majesty’s Revenue and Customs (HMRC), for remarks he made about Patrick McKenna, founder of the Ingenious Media Group, in an interview in The Times in […]

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Sam Allardyce, HMRC

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

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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