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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 …
No litigation privilege in advice from accountants on tax structure
In a recent decision, the High Court has held that advice from accountants on a proposed new tax structure was not prepared for the dominant purpose of …
Notification of Uncertain Tax Treatment - our response to the Consultation
In March 2020 Her Majesty’s Revenue and Customs (“HMRC”) released a consultation document (the "ConDoc") regarding a new proposal to bring forward …
Mixed-use FinTech services not covered by the Investment Management Exemption
In BlackRock Investment Management (UK) Ltd v HMRC (C-231/19), the Court of Justice of the European Union (the "CJEU") held that management services …
Place of Supply AG Opinion
Advocate General Hogan has delivered his opinion in Wellcome Trust Ltd (C-459/19), setting out his view that a "taxable person" who receives services …
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 …
Tax Appeals: Don't Forget ADR
The President of the First-tier Tribunal (Tax) (the "Tribunal”) has today published a practice statement (the “Statement”) on the Tribunal’s approach to …
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 …
Relief for management expenses: Centrica v HMRC examined
The Centrica decision is about whether certain expenses incurred by the taxpayer in making a corporate disposal were deductible as "expenses of …
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 …
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