Preparing for the Possibility of a Domicile Enquiry

Author: Helen McGhee, - 01 Aug 2022
HMRC | Non-Doms | Non-Dom Status | Tax Evasion | Tax

Helen McGhee, a director and chartered tax advisor at Joseph Hague Aaronson, explores who might be vulnerable to an HMRC enquiry on domicile and how best to deal with such enquiries.

Read More

The Kittel Principle - Sweet Sixteen

Author: JHA - 24 Jun 2022
HMRC | Tax

The following is an article written by David Bedenham about HMRC’s wide-ranging application of the ‘Kittel principle’. The current focus appears to very much be on the labour supply industry and the allegation of ‘Mini Umbrella Company Fraud’ (or ‘MUC Fraud’).  This article highlights the need for taxpayers to get specialist advice at an early stage when faced with a Kittel decision. If you have any queries about Kittel-related issues or similar denials of input VAT or assessments to VAT, please contact Iain MacWhannell (

Read More

What is domicile and why does it matter for tax?

Author: Tom O’Reilly, - 13 May 2022
HMRC | Tax | Private Client

A quick review of the fundamental principle of domicile, why it matters for tax, and what the current political landscape has in store.

Read More

Tax note: Financial Institution Notices (FIN)

Author: Nahuel Acevedo-Peña, - 10 Mar 2022
HMRC | Tax Transparency

Understanding paragraph 4A of Schedule 36 to the Finance Act (“FA”)

Read More


Author: Nahuel Acevedo-Peña, - 10 Mar 2022
HMRC | Tax Litigation Cases | Tax Litigation

Short Case Report on FTT Decision Excise Duty

Read More

Fast Track for Register of Overseas Entities Owning UK Property

Author: Helen McGhee, - 08 Mar 2022

The invasion of Ukraine has prompted the UK government to speedily publish the draft legislation for the Economic Crime (Transparency and Enforcement) Bill 2022 which requires foreign entities that acquire UK property (freehold interests or leases granted for more than 7 years) to register with Companies House and declare details of their beneficial ownership.

Read More

Global Minimum Tax on Corporations: OECD GloBE Model Rules and their implementation in the UK

Author: Nahuel Acevedo-Peña, - 22 Feb 2022

This article is a follow-up to our two previous articles of 20 August 2021 and 7 December 2021.

On 8 October 2021, the OECD/G20 published a statement confirming that 136 jurisdictions1 had agreed to a two-pillar solution to address the tax challenges that arise from the digitalisation of the economy and setting out an implementation plan.

Read More

SHORT CASE REPORT FTT DECISION – ‘MTIC’ FRAUD – KITTEL TEST PTGI International Carrier Service Limited v. HMRC [2022] UKFTT 20 (TC)

Author: Nahuel Acevedo-Peña, - 21 Jan 2022

  1. A so-called “MTIC case”, in which HMRC alleged knowledge or means of knowledge of fraud.  The taxpayer, PTGI, denied those states of knowledge.  After a relatively lengthy trial, the Tribunal allowed the appeal of PTGI.
  2. The decision represents a good reminder that HMRC’s “MTIC” decision-making mould is not a “one size fits all”, unbeatable formula at the Tribunal.  The Tribunal will robustly analyse HMRC’s (usually) inference-led allegations.

Read More

HMRC consultation on the OECD mandatory disclosure rules

Author: Helen McGhee, - 13 Jan 2022

HMRC has published a consultation on draft regulations to implement the Organisation for Economic Cooperation and Development (OECD) rules on mandatory disclosure of certain avoidance arrangements. Helen McGhee and Nahuel Acevedo-Peña explain the background to the new rules and their implications.

Read More

Post-Prudential: Decision released by the FTT

Author: Megan Durnford, - 13 Jan 2022

On 8 December 2021, judgment in the Post Prudential Group Litigation was handed down by the First-tier Tribunal (Tax Chamber) (“FTT”). These were appeals and applications for closure by approximately 200 taxpayers, who had made a variety of claims seeking repayment of unlawful DV tax imposed on dividends received from foreign portfolio holdings. The FTT considered the validity of these various statutory claims following decisions in test cases in the CFC & Dividend GLO, namely Claimants in Class 8 of the CFC and Dividend Group Litigation v Revenue and Customs Commissioners [2019] EWHC 338 (Ch), [2019] 1 WLR 5097 (“Class 8”) and Prudential Assurance Co Ltd v HMRC [2018] UKSC 39; [2019] AC 929 (“Prudential SC”).

Read More
 < 1 2 3 4 >  Last ›