HMRC ignores its own behaviour on “Nudge Letters”

It seems that HMRC is immune to the very behavioural techniques which it has so enthusiastically adopted (such as the use of “nudge letters”) to influence taxpayers’ behaviour in complying with the UK tax legislation. In our blog on nudge...

Nudging HMRC to be more transparent with its nudge letters

In recent months, HMRC’s Risk and Intelligence Service (RIS) has once again issued “nudge” letters to individuals who HMRC believes have offshore income and gains that could be liable to UK tax. The “nudge” letters we have seen were issued...

Double tax treaty could not prevent transfer of asset abroad provisions from applying

In the case of Davies and others v HMRC [2018] UKFTT 0559 (TC), the First Tier Tax Tribunal (FTT) has held that the appellants were subject to tax as a result of the transfer of assets abroad rules at s720...

Offshore Developments – More Ammunition for HMRC

There was a time when arranging your affairs to minimise your liabilities was considered tax planning. Invariably this involved steps which included offshore structures. Nowadays the very mention of the phrase has very negative connotations and has become the byword...

Requirement to Correct – Time is running out

In February this year we reported on yet another addition to HM Revenue and Customs (HMRC) ever expanding armoury in persuading people with offshore assets to come forward. As we noted then this is the stick which is now being...

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...

Extending assessment time limits for offshore income, gains or chargeable transfers

HMRC has issued a consultation seeking views on the extension of the four and six year time limits for assessing cases involving loss of tax from offshore income, gains or chargeable transfers, to 12 years. The consultation indicates the reason...

Offshore disclosure facility and requirement to correct

HMRC has issued an update to its note about offshore disclosure facilities and the legislation introduced in F(No2)A 2017 s.67 and Sch18.  This new legislation requires persons who have any uncorrected offshore tax non-compliance for any period before 6 April...

Paradise Islands are no longer heavenly………………

As reported in our previous blog the International Consortium of Investigative Journalists (ICIJ) continues its ongoing campaign to shed the opaque veil that masks offshore financial centres. The ICIJ has received nearly 13.4 million documents from a combination of leaked files...

World-wide Disclosure Facility- HMRC may allow additional time to comply and a clearance procedure

The World-wide Disclosure Facility (WDF) is the only disclosure facility that officially remains open for settling arrears of tax with HMRC. Taxpayers may use the WDF to correct a past failure to pay income tax, CGT (but not non-residents’ CGT)...

Do you have an interest in or connection to an offshore asset or entity?

If you have an interest in or a connection to an offshore asset or entity (“offshore arrangements”) you are likely to attract the unwanted attention of HM Revenue and Customs (“HMRC”) even though they may have been set up for...

Big Brother Requires You to Confess – and Correct Your Sins

One sometimes wonders whether the Government has taken its inspiration from George Orwell’s 1984 or whether it is a symptom of HMRC’s decreasing staff resources but, increasingly, we see legislation that places the burden upon taxpayers to confess all their...