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Mutual mistake and rectification: lessons to be learned from MV Promotions v TMG
A number of important points emerge from the recent decision in MV Promotions Limited and Micheal Vaughan v Telegraph Media Group Limited and HMRC [2020] …
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 …
Lloyd-Webber v HMRC: Music to off-plan investors' ears?
In a decision that will be a welcome source of comfort for investors in potentially risky off-plan property developments, the First-tier Tribunal (Tax) …
High Court strikes out claim against banks in their capacity as lenders to investors of a tax deferral scheme
The High Court has struck out claims brought by former investors in the Ingenious Media tax deferral schemes against lending banks who advanced sums to …
Government announces review of implementation of IR35 private sector reforms
The government announced on 7 January 2020 that it is launching a review of the implementation of the changes to off-payroll working rules (commonly …
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