When will HMRC pull their finger out on ‘phoenixing rules’?

On 25 July HMRC amended their guidance on the much maligned targeted anti-avoidance rule (or ‘TAAR’). When I heard this I…

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Offshore tax disclosure deadline looms

Three months remain… There are now only three months remaining for clients to tidy up their offshore tax affairs before the…

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Where are we with Alternative Dispute Resolution (ADR)?

What is Alternative Dispute Resolution (ADR)? In a tax context, ADR has now been around for a few years but is…

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Big fines for non UK residents in respect of late capital gains returns

The Issue Since 6 April 2015 any disposal of UK residential property falls within the UK tax regime. There is now…

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‘Scary’ HMRC document suggests further clamp down on schemes

Background The latest consultation considers granting additional powers to HMRC to tackle tax avoidance. The effects will be wide ranging and…

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Can we still extract reserves at 10%?

Background HMRC continue their battle against taxpayers who seek to extract funds from their companies at low 10% Entrepreneurs’ Relief rates…

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Successful challenge to Advance Payment Notices

HMRC has withdrawn certain Advance Payment Notices it issued when faced with a judicial review. The APNs were challenged by City…

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Autumn Statement 2015

There was much negative speculation about today’s Autumn Statement. This was fed in part by the fairly dramatic budget in July…

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The Liechtenstein Disclosure Facility (LDF) is closing

In recent years HMRC has successfully operated a number of different disclosure facilities through which individuals could come clean on undisclosed…

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Advance Payment Notices (APNs) are here to stay

The High Court has heard a Judicial Review that was looking to challenge whether APNs are lawful. Taxpayers who had received…

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