Apple and Ireland Win €13bn State Aid Appeal
The General Court of the European Union has today annulled the Commission’s decision regarding two Irish tax rulings in favour of Apple. The Commission had considered that the two rulings constituted State Aid, granting Apple €13bn in unlawful tax advantages.
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The Price of Property
Helen McGhee looks at the present state of UK tax rules that must be considered when owning and disposing of UK property.
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Inheritance tax problems in Finance Bill 2020
The rules on excluded property trusts are due to change with effect from royal assent. These changes are complex, and the new rules can have an unexpected and retroactive effect. Emma Chamberlain explores these rules to determine whether it may be necessary to exclude the settlor going forward as a beneficiary.
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Trust Registration Service- 5MLD update
HMRC’s Trusts and Registration Service (TRS) was born back in 2017 as part of the implementation of 4MLD. 5MLD has mandated notable amendments to the operation of the TRS that clients and practitioners should not overlook. We have created a Q&A to help to navigate the new upcoming compliance obligations.
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DAC6 – delayed but be alert!
Helen McGhee discusses the announcement by the European Commission, proposing to delay disclosure deadlines imposed by DAC6 by three months.
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A legislative flood
Helen McGhee asks whether the deluge of new legislation designed to prevent tax avoidance has really been necessary
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Comment: How to reform inheritance tax
The current IHT system is generally regarded as unsatisfactory and generates relatively small sums for HMRC, comprising less than 1% of total tax revenues. Emma Chamberlain OBE discusses the potential for changes to the IHT provisions.
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How to handle the reservation of benefit provisions
The reservation of benefit legislation continues to be relevant to IHT planning, and the 2017 changes to foreign domiciliaries have extended its scope and importance. Emma Chamberlain provides a practical guide to navigating the rules.
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HMRC restarts paused tax investigations
Tax receipts were down by £26 billion in April as the UK’s economy was hit by the coronavirus crisis. HMRC has it seems now quietly resumed taxpayer investigations which had been put on hold at the peak of the pandemic.
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Latest Development in Inverclyde
Following the hearing in the Upper Tribunal last month, a decision has now been issued, confirming the correct approach for enquiring into returns filed by limited liabilities partnerships who are found not to be trading with a view to profit.
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