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Royal Bank of Canada: A common sense approach to tax treaty interpretation
Introduction In Royal Bank of Canada v HMRC [2023] EWCA Civ 695, the Court of Appeal upheld the taxpayer's appeal in a case relating to the …
Danish WHT fraud claim dismissed
The High Court in Skatteforvaltningen v Solo Capital Partners LLP & Ors [2021] EWHC 974 (Comm) ("Solo Capital") has dismissed claims brought by the …
Latest thinking from HMRC on offshore compliance
Within the framework of its "No Safe Havens" tax compliance strategy, HMRC has published two discussion papers concerning aspects of the administration …
SFO'S extra-territorial reach more limited than HMRC'S, at least for now
The Supreme Court has handed down judgment in the case of R (on the application of KBR, Inc) (Appellant) v Director of the Serious Fraud Office …
DAC 6 Reporting Deferred in the UK
The UK government has today announced that the first reporting deadline under DAC 6 will be deferred for 6 months to allow taxpayers and advisors …
High Court offers sympathy but no remedy to trustee facing unexpected tax bill
In Mackay v Wesley [2020] EWHC 1215 (Ch), the Claimant, who was instructed by her father to become a trustee of a family trust as …
Tax Treaty Interpretation: The Limits of Fiction
In Fowler v HMRC [2020] UKSC 22, the Supreme Court determined that a statutory fiction created by a deeming provision of UK tax law did not …
HSF Trust Companies Survey - Tax Insights
We asked trust companies questions about the most significant risk and compliance issues they face. The survey mapped which specific tax compliance …
Rapid resolution of domicile disputes: be careful what you wish for
In Henkes v HMRC [2020] UKFTT 7645 (“Henkes”), the First-tier (Tax) Tribunal (“the Tribunal”) held that (a) it could (and would) …
HMRC guidance on statutory residence test and COVID-19
HMRC has updated its guidance on the Statutory Residence Test (“SRT”) to extend the exceptional circumstances disregard to cover COVID-19. When …
The extra-territorial reach of HMRC's investigatory powers
In R (on the application of Jimenez) v the First-tier Tribunal (Tax Chamber) and HMRC ("Jimenez"),1 the Court of Appeal determined that HMRC had …
When can trustees assert privilege?
Recording: Originally broadcast: 31 October 2017 Faced with requests for disclosure (including from regulators and tax …
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