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Helen McGhee TEP, Elizabeth Dean and Megan Durnford consider HMRC’s ever-expanding criminal investigation powers

UT considers taxpayer’s application for permanent anonymity and third-party disclosure request (HMRC v The Taxpayer and Others)

The Upper Tribunal (UT) rejected a taxpayer’s application for permanent anonymity, following the taxpayer's decision to withdraw their substantive appeal with the First-tier Tax Tribunal (FTT). The UT further granted a third party limited access to the FTT’s previous case management decision. The UT’s decision emphasises the importance placed on open justice and highlights the court and tribunals’ reluctance to permit anonymity in litigation.

PRIVATE CIENT BUDGET UPDATE

The new rules are complex and what follows is an overview. The non dom changes will be effective from 6 April 2025. No changes have been made to the statutory residence test (SRT) effective for UK tax purposes from tax year 2013/14 onwards (prior to then the common law determined UK residence status for tax purposes).

THE END OF THE REMITTANCE BASIS AND THE TWO TRANSITIONAL PROVISIONS

Tax year 2024/25 (the current year) marks the last year that eligible individuals will be able to make a remittance basis claim. From 2025/26 the remittance basis will be replaced with the 4-year FIG regime. There is no amnesty for existing foreign income and gains that were previously sheltered by the remittance basis regime and have not yet been taxed. Any remittance to the UK after 5 April 2025 will be subject to taxation just as it was before, albeit the new legislation:

REVIEW OF ANTI-AVOIDANCE LEGISLATION

A 29 July 2024 government policy paper announced that there would be a review of the offshore anti-avoidance legislation.

Budget Speculation

With the highly-anticipated Budget due to be delivered on 30 October 2024, Helen McGhee and Lynnette Bober explore how this event is likely to impact taxpayers.

JHA ranked in top tier again in Chambers UK 2025

We are happy to announce that JHA's Tax Disputes Team has again been ranked as Band 1 by Chambers today, a ranking we have proudly achieved every year since we began in 2013. A special congratulations to our lawyers who also received individual recognition: Graham Aaronson KC (Band 1), Simon Whitehead (Band 1), Michael Anderson (Band 2)  Iain MacWhannell (Band 4) and Paul Farmer (Senior Statespeople).

This is the latest successful ranking, following previous top-tier rankings in Legal 500 United Kingdom 2025 and Chambers High Net Worth Guide 2024.

The Proposed Changes to Domicle - A Fundamental Rethink is Required

There is a great deal of support for abolishing domicile as a fiscal connecting factor for tax purposes and replacing the remittance basis of taxation with a much-simplified residence-based regime. In principle, everyone can agree with Labour that the tax system should be made fairer: “If you make your home and do your business in Britain, then you should pay your taxes here too”.

JHA ranked in top tier again in Legal 500 UK 2025

We are happy to announce that JHA's Tax Disputes Team has again been ranked as Tier 1 by Legal 500 today, a ranking we have proudly achieved every year since we began in 2013. A special congratulations to Graham Aaronson KC who has again been recognised in the Hall of Fame category, Iain MacWhannell (ranked as a Leading Partner) and Mei Wong (ranked as a Leading Associate).

This is the latest successful ranking, following previous top-tier rankings in Chambers UK Legal Guide 2024 and Chambers High Net Worth Guide 2024.

Q&A: transfer pricing methods in United Kingdom

Graham Aaronson, Michael Anderson and Steve Bousher provide answers to common questions on transfer pricing methods.