Our Insights

COVID-19: European Commission’s Big Plan

The coronavirus pandemic has had a great impact on countries across the world. With such a wide-ranging knock to the global economy, the European Commission released a communication on 27 May 2020, setting its plan for recovery in Europe.

Digital Service Tax

For some years now, the OECD have been working towards an international approach to the taxation of digital businesses. Be that as it may, delay in the international implementation of this tax has resulted in many countries now enacting their own tax laws on digital services. The United Kingdom is one such country.

Loss Relief: The Give and The Take

The introduction of the Finance Bill 2020 brings with it a relaxing of the conditions required to qualify for the share loss relief scheme. On the other hand, it also implements the Corporate Capital Loss Restrictions which were first announced in Budget 2018.

Exit charges

As announced in July of last year, the 2020 Budget introduces a new deferred payment plan option for Corporation Tax charged on profits or gains arising from certain transactions between UK companies and EEA companies of the same group of companies.

Reversal of Inverclyde

The 2020 Budget announced provisions to reverse last year’s FTT decision in Inverclyde. In that case, HMRC denied the appellant LLPs’ claims for Business Property Renovation Allowance on the basis that the LLPs did not carry on a business with a view to a profit. 

HMRC nudge letters

HMRC continues to fight the good fight in its quest to cut down on tax avoidance and have recently been issuing further “nudge” letters to taxpayers who may have an income source or assets producing gains overseas and consequently an undisclosed outstanding UK tax liability.

ExxonMobil: FTT Decision Released

The FTT decision in Esso Exploration and Production UK Limited and others v HMRC, which relates to pre-2006 claims for Cross Border Group Relief, has now been released.

Ingenious LLPs v HMRC – Permission to appeal partially granted

In the latest instalment of the long-running dispute over various film and game investment schemes, the Court of Appeal grants partial permission for the appeal to be heard in its court.

Guidance released on new Double Tax Dispute Resolution

First Insight into HMRC’s use of Corporate Criminal Offences Powers