Autumn Statement 2016 – views from the market
Originally published in Lexis®PSL Tax Analysis on 28 November 2016.
It seems that the proverbial white rabbit was the announcement of the single annual fiscal event. After the Spring Budget next year and the consequent Summer Finance Bill, from Autumn 2017 the Budget and Finance Bill cycle will move to the Autumn. Draft clauses for the next finance bill will be published in the Summer. This should allow longer and better debate before the clauses are enacted. There will still be a Spring Statement (from Spring 2018) in response to the OBR’s Spring forecast but normally the government would not use that Spring Statement to announce tax changes. The Chancellor intends that changes to the tax system should be announced in the Autumn. On balance this looks to be an improvement to the system and the CIOT and the IFS called for this change in an open letter back in September.
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Navigating Domicile Enquiries: Recent Case Review
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  UK FTT 539 (TC), Strachan v HMRC  UKFTT 00617 (TC) and Coller v HMRC  UKFTT 212 (TC).
Mini Umbrella Companies (“MUCs”) Success at Tribunal (Labour Supply; Kittel fraud; Fini fraud)
Iain MacWhannell, instructing David Bedenham, successfully represented an employment intermediary in an appeal against a denial of input tax and £15 million VAT assessment.
The End is Nigh for the Non-Dom Regime
Published in ThoughtLeaders4 Private Client Magazine, Helen McGhee expert analysis of the current state of non-dom tax regime and it's future.
HMRC Makes Changes to COP9
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.
Pandora Papers: HMRC issues nudge letters
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.