income tax

The benefits of an Independent Review by HMRC

The Taxes Acts allow taxpayers to ask for an independent review of an appealable decision by HMRC. The review is carried out by an independent officer within HMRC’s Appeals and Reviews teams. However, recent evidence suggests that many taxpayers remain...

Offshore Royalty Payments

The Government will apply income tax to offshore businesses making offshore royalty payments in respect of intangible property used to generate UK sales. This will apply from 6 April 2019. The charge will apply unless the entity is UK resident or...

Draft Welsh Budget for 2019/20

The Welsh Government has published its Budget proposals.  Pages 16 – 22 of the Outline Budget Narrative cover tax policy and tax rates.  In summary the highlights are: Welsh rates of income tax will not differ from those in the...

Finance Bill 2018-19 – tax administration points

Included in the draft finance bill legislation issued on 6 July 2018 on those measures affecting tax administration, were provisions relating to extension of offshore time limits for assessing certain taxes, extension of the security deposit regime, and profit fragmentation....

UK Government does the dance of transparency!

In a backbench revolt on 1 May 2018 the UK Government was forced to back new legislation which will introduce public ownership registers in Britain’s 14 overseas territories.  The concept of public ownership registers was originally proposed by David Cameron...

Yet another nail in the coffin for offshore arrangements?

The UK Government has introduced a raft of legislation to address tax evasion and latterly tax avoidance. This has included; The Requirement to Correct legislation which has introduced punitive offshore penalties and extended assessing time limits for Income Tax, Inheritance...

Self-funded work related training

One of the areas where a consultation was announced was training; specifically the difference in treatment between training that an individual funds personally and that paid for by an employer. This is a key area of Government focus given the...

Scottish and Welsh taxes update

The process of devolving tax powers is well underway and we can expect to see a number of major changes in the following months and years. As regards Scotland, Revenue Scotland (RS) have an excellent web-site (which can be accessed...

HMRC roots out yet another success…

The recent decision in HMRC v Root2tax Ltd and Root3tax Ltd [2017] UKFTT 696 (TC) has demonstrated yet again HMRC’s determination to challenge promoters of tax planning arrangements who fail to disclose under DOTAS (Disclosure of Tax Avoidance Schemes) schemes...

Trouble aboard the good ship HMRC?

It is said that the real sign that a ship is in trouble is not when the rats jump overboard but when the officers abandon it mid-voyage. If that’s the case, HMRC appears to be sinking because a number of...

A Budget for Working Families?

The government made a commitment to raise the personal allowance to £12,500 and the higher rate threshold to £50,000 by the end of this parliament. The measures announced today have been billed as a step towards achieving this objective. The...

Tax rates and Locks

Leaving aside the niceties of a government feeling it necessary to impose a law on itself it is telling to consider what is and isn’t within the scope of the tax lock. We have been told that the target is...

Doomed to be misquoted?

Occasionally a Tax Case is published and, even at its first reading, the heart of the experienced tax investigations practitioner sinks as he realises that the case is likely to be misquoted by HMRC as supporting such-and-such a principle. For...

High profile ‘Working Wheels’ tax scheme fails

Last weekend’s press had headline stories of the First Tier Tribunal (FTT) decision in Flanagan & Others v HMRC that the “working wheels” tax scheme was not effective.  The press particularly highlighted the involvement of Chris Moyles, the former Radio...

OTS Review of Employee Benefits and Expenses

The Office of Tax Simplification (OTS) has now issued its second report on its review of employee benefits and expenses and the complexities in current legislation in this area.  This report suggests radical reforms, building on the interim report issued...

Waived dividends taxable under settlements rules

In P Donovan and related appeal (TC03188) the First Tier Tribunal rejected taxpayers’ appeals against HMRC’s determination that dividends paid to their wives should be assessed on them under ITTOIA 2005 s 624 (settlements in which the settlor retains an...

RDR3: guidance note on the statutory residence test

In December HMRC published a new guidance note, RDR3 which provides specific guidance on the statutory residence test (SRT). This guidance sits alongside the existing guide RDR1 - Residence, domicile and the remittance basis. Note - these are the only...