HMRC Business Brief on Settlement of Statutory Double Tax Relief Claims Affected by the FII and CFC Dividend GLOs
Many of our clients have made various historical claims for repayment of tax on dividend income. On Friday 24 January 2020 HMRC sent JHA a “business brief” outlining their approach to resolving these claims. In summary, HMRC say they will now accept as valid claims, in-time exemption filings with open enquiries, taxable filings with DTR claimed at the ULT rate and DTR claims outside the return within the s806(1) ICTA time limits. The above also follows for pay and file years where there is an assessment and an appeal.
Other claims are less certain. The brief suggests returns amended on an exemption basis will be dealt with on a case-by-case basis and is entirely silent on error or mistake claims. HMRC have indicated they will contest any claim failed outside the strict statutory time limits. Nevertheless, the brief is an encouraging development.
Draft Finance Bill 2020–21—promoters and enablers of tax avoidance schemes
Helen McGhee, senior associate at Joseph Hage Aaronson LLP, shares her insights on the Draft Finance Bill 2020–21 and its impact on promoters and enablers of tax avoidance schemes.
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.
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.
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.
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.