Is it OK to breach transactions in securities legislation?

Transactions in securities legislation (TISL) has been around for a long time and the legislation has gone through some changes, most…

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Avoid discovery assessments with proper disclosure

Discovery assessments Generally a tax payer should have certainty about their tax affairs and this means that HMRC should not be…

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Is Lorraine Kelly a tax avoider or a celebrity scapegoat?

The papers have recently been rife with stories of how TV presenter, Lorraine Kelly, won an appeal at a First Tier…

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HMRC threatens follower notices on loan write-offs

The issue Before Finance Act 2010 made amendments to the legislation there was a fairly widespread piece of tax planning in…

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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HMRC has withdrawn certain Advance Payment Notices it issued when faced with a judicial review.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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