The approach of the Tax Tribunal to evidential sampling in Kittel cases

Author: Iain MacWhannell, - 24 May 2024
VAT | Tax Litigation Cases

Case Note: ‘The approach of the Tax Tribunal to evidential sampling in Kittel cases

The First-tier Tribunal (Tax Chamber) has recently published a decision of Judge Dean on a sampling application by HMRC in the case of Ezy Solutions Ltd (in liquidation) and Milo Corporation Ltd (in liquidation) v HMRC [2024] UKFTT 00209 (TC). The Decision was released on 9 March 2023 but had not been published until recently.

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VAT Umbrella Appeals Decision

Author: JHA - 16 Apr 2024

On 27 March 2024, the Tax Tribunal released its Decision in the VAT Umbrella Appeals.

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Private Client Tax Budget Update

Author: Lynnette Bober, - 07 Mar 2024
HMRC | Non-Doms | Tax Litigation | Non-Dom Status | Tax

Spring Budget 2024 was littered with the usual political posturing and some ineffective tinkering. Unfortunately fiscal drag will continue to be significant. Wednesday 6 March 2024 was also an earth-shattering day for the non-UK doms and all those who advise them.

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Navigating Domicile Enquiries: Recent Case Review

Author: Helen McGhee, - 17 Oct 2023
HMRC | Non-Doms | Tax Litigation | Non-Dom Status | Tax

In recent months, the First-tier Tax Tribunal has presided over 3 headline grabbing domicile cases which, whilst offering little precedential value, set out some useful commentary on the multi factorial approach taken by HMRC and ultimately the tribunal in determining an individual’s domicile status. This note reviews the decisions made in Shah v HMRC [2023] UK FTT 539 (TC), Strachan v HMRC [2023] UKFTT 00617 (TC) and Coller v HMRC [2023] UKFTT 212 (TC).

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Mini Umbrella Companies (“MUCs”) Success at Tribunal (Labour Supply; Kittel fraud; Fini fraud)

Author: Iain MacWhannell, - 05 Oct 2023
VAT | HMRC | Tax Litigation | Tax

Iain MacWhannell, instructing David Bedenham, successfully represented an employment intermediary in an appeal against a denial of input tax and £15 million VAT assessment.

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The End is Nigh for the Non-Dom Regime

Author: Helen McGhee, - 18 Jul 2023
Non-Doms | Tax Avoidance | Non-Dom Status | Tax Evasion | Tax Transparency | Tax

Published in ThoughtLeaders4 Private Client Magazine, Helen McGhee expert analysis of the current state of non-dom tax regime and it's future.

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HMRC Makes Changes to COP9

Author: Helen McGhee, - 26 Jun 2023
HMRC | Tax

On 14 June 2023, HMRC published a substantially rewritten Code of Practice 9 (“COP9”). Helen McGhee and Megan Durnford set out the key changes implemented as a result of this publication.

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Pandora Papers: HMRC issues nudge letters

Author: Helen McGhee, - 19 Jun 2023
HMRC | Investigation

The Pandora Papers leak of almost 12m documents back in 2021 purportedly exposed the secret accounts and dealings (including potential tax evasion/ avoidance and money laundering) of 35 world leaders (including the late HM Elizabeth II), as well as many politicians and billionaires. The data was obtained by the International Consortium of Investigative Journalists in Washington DC and led to one of the biggest ever global financial investigations.

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Increased Investment in Personal Tax Compliance in the UK (Published in Thought Leaders 4 Private Client)

Author: Helen McGhee, - 29 Nov 2022
Tax Transparency | Tax

Advances in technology and increased international fiscal co-operation have made global personal tax compliance initiatives pop up in abundance in recent years. To compound the issue, the Russian invasion of Ukraine and the corresponding economic fallout prompted domestic governments to increase transparency in relation to investments held by wealthy foreign individuals (with a focus on oligarchs).

In the UK, in the context of the cost-of-living crisis, public opinion certainly seems to be in favour of increased accountability for high-net-worth individuals (eg, on 9 October 2022, 63% of Britons surveyed thought that “the rich are not paying enough and their taxes should be increased”).1

HMRC is one of the most sophisticated tax collection authorities in the world and the department is making significant investments in technology in the field of compliance work; they are well placed to take advantage of new international efforts to increase tax compliance, particularly considering the already extensive network of 130 bilateral tax treaties in the UK (the largest in the world).2 The UK was also a founding member of the OECD’s Joint International Taskforce on Shared Intelligence and Collaboration (JITSIC) forum.

This article discusses the main developments in support of the increased focus on international transparency and personal tax compliance in the UK. There are other international fiscal initiatives, particularly in the field of corporate taxation, but such initiatives are beyond the scope of this article.

It should be noted that a somewhat piecemeal approach, with constant tinkering makes compliance difficult for the taxpayer and is often criticised for lacking the certainty that a stable tax system needs to thrive.

This article was first published with ThoughtLeaders4 Private Client Magazine

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Tax-Related Measures in the Autumn Statement 2022

Author: Nahuel Acevedo-Peña, - 21 Nov 2022
Corporation Tax | Income Tax | Tax Avoidance | Tax Evasion | Tax Transparency | Tax

On 17 November 2022, the Rt Hon Jeremy Hunt MP, the Chancellor of the Exchequer, unveiled the contents of the Autumn Budget 2022. This comes after the International Monetary Fund (IMF) published its world economic forecast on 11 October 2022. The IMF expects the British economy to grow 3.6% in 2022 and 0.3% in 2023. Other major developed economies are also expected to stagnate next year, namely Spain (1.2%), the US (1.0%), France (0.7%), Italy (-0.2%) and Germany (-0.3%).

This note focuses on tax measures included as part of that statement.

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