UK corporate offence of failure to prevent tax evasion
Welcome to the May edition of our UK Tax Round Up, which discusses two interesting judgments, one on the question of whether a distribution from a Jersey company was of a “capital nature” and the other on whether a loan to a...more
In Syngenta Holding Limited v HMRC [2024] UKFTT 998 (TC) (“Syngenta”), the UK’s First-tier Tribunal (“FTT”) denied a deduction for interest on an intra-group loan on the basis that the loan had an unallowable purpose for the...more
Budgets are normally stories of two halves. The first half contains the headline-grabbing tax policy reforms that can be encapsulated in a snappy soundbite in the Budget speech, such as “Chancellor scraps the non-dom regime”....more
Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more
Welcome to March’s edition of the UK Tax Round Up. This month’s edition features comments on the recent Spring Budget together with a summary of some recent case law involving VAT due on services provided to ex-VAT group...more
Whilst the default position is that supplies of land and buildings are usually exempt from VAT (the sale of new commercial buildings excepted), landowners of commercial property will often choose to opt to tax their property...more
Welcome to November’s edition of the UK Tax Round Up. This month has seen publication of the Finance Bill 2021-22 (what will become the Finance Act 2022) including draft legislation for the basis period reform, UK asset...more
UK Case Law Developments - Income tax consequences of pension-related payments in E.ON v HMRC - E.ON v HMRC concerned a large UK power and gas supplier, which paid certain lump sum payments, called “facilitation...more
Spring Budget and Tax Day - After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more
Following a pandemic-related delay, significant changes to the IR35 regime come into force on 6 April 2021. From then, affected businesses which engage contractors who provide services through their own limited company...more
UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more
On March 3, 2021, the U.K. government announced its 2021 Spring Budget (the “Budget”) which contained a number of extensions to measures designed to support the country even after our expected emergence from lockdown. ...more
In this issue of UK Employment Flash, we examine the latest employment law developments, news and insights from the UK, including considerations for employers requiring staff to get the COVID-19 vaccine, the delayed rollout...more
From the beginning of the UK’s first lockdown in March of last year we have reported on the impact of the pandemic on individual and corporate tax residence and permanent establishment risk. In April 2020 the OECD...more
COVID-19 Developments - Tax exemptions for coronavirus antigen costs - Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover...more
In HMRC v Development Securities, the Court of Appeal (the “CA”) has overruled the Upper Tribunal and agreed with the First-tier Tribunal that the relevant Jersey incorporated subsidiaries of a UK parent were resident in the...more
UK COVID-19 Developments - Extension of support for employed and self-employed workers - On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more
Quick Summary. In the United Kingdom, Her Majesty’s Revenue and Customs (HMRC) is responsible for administering and collecting taxes in the UK. For 2019, HMRC collected $841.19 billion in tax revenue. But it took over 300...more
UK COVID-19 Developments - UK Prime Minister’s statement on COVID-19 - On 31 October, the Prime Minister announced a number of measures designed to slow down the spread of COVID-19 to last for four weeks from 4...more
Finance Act 2020: This Time It’s Personal (Liability) - The Finance Act 2020 introduces new rules which make certain individuals who have a ‘relevant connection’ to a company that is, or is likely to become, subject to an...more
UK COVID-19 Developments - HMRC updates its trading activities guidance - HMRC has updated its guidance at BIM48000 regarding how legislation and case law should be applied where a business makes changes to its...more
UK COVID-19 developments - Proposed deferral of DAC6 and DAC2 - The European Commission has published a draft directive proposing a three month delay to the deadlines for certain information disclosures under the EU...more
There has been much discussion over the past year or so about the UK government’s proposal to make changes to the application of the off-payroll working (or IR35) tax rules to private sector end clients so as to shift certain...more
The UK’s First-tier tax tribunal (FTT) has just released an interesting decision considering whether or not expenses incurred by a parent company on advisers’ fees that related to a proposed disposal by a group subsidiary and...more
Temporary changes to the statutory residence test for inbound COVID-19 workers - The UK Chancellor has written to the chair of the Treasury Select Committee outlining temporary changes to the statutory residence test...more