The Treasury has finally published its response as required by the Section 95 Finance Act 2019 (FA2019). Section 95 FA 2019 was an amendment to FA 2019 which required the Chancellor to review the Disguised Remuneration Loan Charge (“Loan Charge”)....
For participants in what HMRC calls Disguised Remuneration tax avoidance, we previously reported in August 2018 the details of what is the final settlement opportunity. The “carrot” was stated to be resolution and finality of long standing investigations with the...
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...
We reported earlier this year on how to take advantage of the final opportunity in settling any liabilities arising from various forms of historic tax planning which HM Revenue and Customs (HMRC) badges under the disguised remuneration banner. We also...
The expectation that HMRC would use the Supreme Court’s decision in the Rangers Case as the basis of issuing Follower Notices and Accelerated Payment Notices has now become a reality. As set out in our previous blog HMRC is required...
If you have used remuneration tax planning involving loans (after 6 April 1999) and choose not to settle with HMRC using the current disguised remuneration settlement opportunity, then any outstanding loans as at 5 April 2019 will be subject to...
In August last year we reported on the announcement of HMRC’s final settlement opportunity for Employee Benefit Trust (EBT) users as a result of the infamous Rangers decision in the Supreme Court. This settlement opportunity is also for Employer Financed...
Investors in Future Capital Partners (“FCP”) investments will most likely have seen or been advised by FCP itself that the company may shortly go into liquidation or administration. This has been reported in various newspapers, including the Financial Times. Participants...
Following the Supreme Court’s decision in the Rangers Football Club Employee Benefit Trust (“EBT”) case last year. HMRC is sending Follower Notices to companies with EBTs, users of Employer Financed Retirement Benefit Schemes (EFRBS) and other (what HMRC terms) similar...
HMRC have been successful at the Upper Tribunal (as it was in the First-tier Tribunal) against the Clavis Liberty Fund. To summarise briefly, the scheme involved a limited partnership that was registered in Jersey and was claiming to carry out...
On 13 September 2017 the First-tier Tribunal released its decision in a case involving an Employee Benefit Trust (EBT). Specifically the planning used by the taxpayers in this case was the “EBT Pro strategy”, but the decision equally applies to other...
Following HM Revenue & Customs (HMRC) success against Rangers Football club (RFC 2012 Plc (in liquidation) (formerly The Rangers Football Club Plc) (Appellant) v Advocate General for Scotland (Respondent) (Scotland) [2017]UKSC 45) use of Employee Benefit Trusts (EBT), HMRC is...
The Marriage (Same Sex Couples) Act 2013 (MSSCA 2013) came into effect on 13 March 2014: enabling couples of the same gender to be legally married in the UK; and recognising overseas same-sex marriages as valid in the UK. The...
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