Joseph Hage Aaronson LLP contributes to the The Legal 500: Tax Country Comparative Guide
JHA's contentious tax team has contributed to the recently published fourth edition of The Legal 500: Tax Country Comparative Guide. This go-to guide provides readers with a pragmatic overview of the Tax laws and regulations across a variety of jurisdictions worldwide. Each chapter covers a different jurisdiction and contains information on withholding tax, transfer pricing, the OECD model, GAAR, tax disputes and an overview of the jurisdictional regulatory authorities. The template for each chapter was provided by JHA's Michael Anderson and Simon Whitehead, who also wrote the UK chapter for the guide. In the past two weeks, JHA's contentious tax team has once again achieved top tier rankings in both The Legal 500 UK and Chambers and Partners UK 2020 guides. JHA remains the only law firm to have achieved such rankings in both guides every year since its inception. Being chosen as a key contributor to this guide, combined with our directory rankings, demonstrates the marketing leading position of JHA's tax team. This has been achieved through the firm's unique combination of expert solicitors, barristers and forensic accountants, as well as its close working relationships with its clients. This approach enables our continued success in dealing with complex, high value and often ground-breaking tax disputes. Read JHA's chapter in the guide here and view the whole guide here.
The Kittel Principle - Sweet Sixteen
The following is an article written by David Bedenham about HMRC’s wide-ranging application of the ‘Kittel principle’. The current focus appears to very much be on the labour supply industry and the allegation of ‘Mini Umbrella Company Fraud’ (or ‘MUC Fraud’). This article highlights the need for taxpayers to get specialist advice at an early stage when faced with a Kittel decision. If you have any queries about Kittel-related issues or similar denials of input VAT or assessments to VAT, please contact Iain MacWhannell (firstname.lastname@example.org).
What is domicile and why does it matter for tax?
A quick review of the fundamental principle of domicile, why it matters for tax, and what the current political landscape has in store.
Tax note: Financial Institution Notices (FIN)
Understanding paragraph 4A of Schedule 36 to the Finance Act (“FA”)
SHORT CASE REPORT FTT DECISION – EXCISE DUTY - Cantina Levorato SRL v. HMRC  UKFTT 461 (TC)
Short Case Report on FTT Decision Excise Duty
Fast Track for Register of Overseas Entities Owning UK Property
The invasion of Ukraine has prompted the UK government to speedily publish the draft legislation for the Economic Crime (Transparency and Enforcement) Bill 2022 which requires foreign entities that acquire UK property (freehold interests or leases granted for more than 7 years) to register with Companies House and declare details of their beneficial ownership.