Recent changes in HMRC’s Risk Assessment process means that a company or partnership that fails to address the Corporate Criminal Offence (CCO) requirements could find themselves facing annual enquiries into their tax affairs. The CCO legislation was introduced just over...
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...
A recent First Tier Tribunal decision in Tasneem Arif v The Commissioners for H M Revenue and Customs [2019] UKFTT 7 (TC) which involved an appeal against an information notice raises the question of what a taxpayer might do if...
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...
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...
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...
Thursday’s 26 October 2017 episode of EastEnders showed that loveable rogue Billy Mitchell was the subject of a HMRC compliance visit. Many of the businesses on the show are portrayed as family owned and managed and Billy is a Partner...
New corporate criminal offences are being introduced for the failure to prevent the facilitation of tax evasion (in respect of UK and overseas tax). As the Criminal Finances Bill received Royal Assent on 27 April 2017, businesses need to press...
There is an old and bad joke that says that the difference between HMRC and a rabid Pit Bull terrier is that, if you batter a rabid Pit Bull Terrier long enough, it might eventually let go, whereas HMRC… But...
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...
The difficulty with the Hidden Economy – like the so-called ‘Tax Gap’ – is that no-one can actually say how big it is. That’s why it’s referred to as being Hidden. It is clear that HMRC believes that the solution...
When does it start and who can use it? On the 5th of September 2016, HMRC finally published details of its new disclosure facility; the Worldwide Disclosure facility (WDF), which will run from the 5 September 2016 to 30 September...
In the past few days HMRC have begun to provide some limited details of the next - and long promised - offshore disclosure facility. Referred to as the Worldwide Disclosure Facility or WDF, the disclosure facility will be open to...
This has been such a year for astonishing events – what with Brexit, Prime Ministers and party leaders resigning left, right and centre, along with terrorist atrocities, attempted coups and disasters on a scale that previously might not be imagined...
The Chancellor and the Treasury have issued a joint Statement on the initiative for exchange of beneficial ownership information, updated on 3 May after the inclusion of Iceland. The activities targeted go beyond tax evasion to include money laundering and...
The Public Accounts Committee (PAC) in its report of 15 April 2016 is critical of HMRC’s approach to addressing tax evasion which includes concerns over its criminal prosecution policy. To be fair to HMRC, it is not possible to undertake...
On 9th May 2016 the International Consortium of Investigative Journalists (‘ICIJ’) undertook the next step in their release of the information obtained from the Panamanian law firm, Mossack Fonseca – the so-called Panama Papers – when they allowed public access...
The International Consortium of Investigative Journalists (ICIJ) announcement that it has received more than 11.5 Million financial and legal records relating to Mossack Fonseca and its exposé of prominent politicians and their families has once again brought tax evasion and...
The furore regarding the “Panama Papers” – the 11.5 million documents leaked from the Panamanian law firm of Mossack Fonseca – would seem to suggest that everyone involved in a Panamanian company must be a serious villain on a par...
Keen to show immediate action on the promise to introduce a new corporate offence for failing to prevent the facilitation of tax evasion (see TTH 15 April 2016), a consultation document ‘Tackling tax evasion: legislation and guidance for a corporate...
In the wake of the Panama scandal, the UK will now bring forward its plans to introduce a new criminal offence for corporations which fail to prevent their staff from facilitating tax evasion. These proposals were first raised at the...
… and the Amazon and the Apple decisions are coming. Although, in the last 12 months, our attention was captured by the G20/OECD BEPS Project today all eyes are on the European Commission’s state aid work. It is undeniable that...
In the Autumn Statement, the Chancellor proudly referred to the £800m that was being invested in tackling tax evasion. But a bit of investigation suggests that we might have heard this song before. Strangely, if a taxpayer were to try...
With the Government signing up to the Tax Lock commitment to not increase mainstream taxes, it has to find extra money from somewhere to reduce the Country’s debt and borrowing requirements. Who is in HMRC’s sights this time? Online traders, wealthy...
The European Commission presented an Action Plan to fundamentally reform corporate taxation in the EU on 17 June 2015. The Action Plan sets out a series of initiatives to tackle tax avoidance, secure sustainable revenues and strengthen the Single Market...
Strengthening the international community’s fight against offshore tax evasion: Australia, Canada, Chile, Costa Rica, India, Indonesia and New Zealand join multilateral agreement to automatically exchange information on 4 June 2015 Today marks another significant step in our collective pursuit to...
The OECD reached a new milestone when the work on the development of the Multilateral Instrument to implement the tax treaty-related BEPS Action Plan began on 27 May 2015 in Paris. As per the OECD/G20 mandate, the ad hoc Group...
The OECD published its revised discussion draft on Action 6 (Prevent the granting of treaty benefits in inappropriate circumstances) of the Action Plan on Base Erosion and Profit Shifting (BEPS) on 22 May 2015. Public comments are invited on the revised discussion...
Commissioner Moscovici highlighted the re-launch of a debate on the Common Consolidated Corporate Tax Base (CCCTB) on 29 April as a part of the EU Commission’s Action Plan. This Action Plan will build on 5 key actions, starting with the relaunch...
The OECD invited public comments on a Discussion Draft which deals with work in relation to Action 8 of the Action Plan on Base Erosion and Profit Shifting (BEPS) on 29 April. Action 8 covers the transfer pricing of intangibles...
On 3 April, the OECD published a Discussion Paper on Action 3 (Strengthening CFC Rules) of the BEPS Action Plan focusing on develop recommendations regarding the design of controlled foreign company (CFC) rules. The Committee on Fiscal Affairs (CFA) invites interested...
The European Tax landscape has dramatically changed in last few months. The Luxembourg tax leaks and the European Commission’s state aid investigations into tax rulings issued by Ireland, Luxembourg and the Netherlands have created huge amounts of press coverage over...
Pierre Moscovici, Commissioner for Economic and Financial Affairs, Taxation and Customs, endorsed the European Commission’s work on Tax Transparency Package, launched on 18 February. He went further and stated "It is time for a new era of openness between tax...
Tax Transparency through information exchange is one of the most important and key items on the agenda nowadays. On 24 February 2015, Seychelles became the 85th signatory of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. The signing of...
On 27 January, the European Council for Financial and Economic Affairs (ECOFIN) had adopted the proposal to include a general anti-abuse provision in the European Union Parent-Subsidiary Directive (recast) (2011). As a follow-up to the Action Plan against tax evasion...
On 16 January 2015, the European Commission published a non-confidential version of a decision taken on 7 October 2014 to open an in-depth investigation into transfer pricing arrangements on corporate taxation of Amazon in Luxembourg. The EU Commission’s preliminary view...
I am wondering whether it is only me who is facing hundreds of pages of discussion documents inviting stakeholders’ input or are you also sharing the same experience while you are drinking your strong cup of coffee today! It is...
Release of discussion draft on revisions to Chapter I of the Transfer Pricing Guidelines (Including risk, recharacterisation and special measures) The OECD has invited stakeholders' input on the discussion draft which deals with work in relation to Actions 8, 9,...
George Osborne delivers the Coalition’s final Autumn Statement in the House of Commons on 3 December. We reckon he’ll use this opportunity to remind us of the economic achievements of the Coalition, but will there be carrots promising reductions in...
Public comments are invited on a discussion draft which deals with follow-up work mandated by the Report on Action 6 (“Prevent the granting of treaty benefits in inappropriate circumstances”) of the BEPS Action Plan on 21 November 2014. The OECD...
Prime Minister Abbott and Treasurer Hockey announced today that the G20 Leaders welcomed OECD recommendations that will help restore fairness, integrity and transparency to the international tax system. The United Kingdom's Prime Minister David Cameron announced during the press...
Today, the Finance Ministers from 51 countries and jurisdictions have signed a Multilateral Competent Authority Agreement on the implementation of the Global Standard for the automatic exchange of financial account information. The signature of the Multilateral Convention on Mutual Administrative...
On 23 and 24 October, Heads of Tax Administration from 38 countries met in Dublin, Ireland for the 9th meeting of the Forum on Tax Administration (FTA). The FTA is the leading international body concerned with tax administration, bringing together...
Monaco deepens its commitment to fight offshore tax avoidance and evasion OECD Secretary-General Angel Gurría welcomed the Principality of Monaco’s commitment to strengthen international tax co-operation, on 13 October, after it became the 84th jurisdiction participating in the Multilateral Convention on Mutual...
We welcome the OECD's continued work on the impact of BEPS in low income countries. The OECD published Part II of a two-part report to the G20 Development Working Group (DWG) on the impact of BEPS in low income countries....
Today, the EU Tax Commissioner Algirdas Šemeta has welcomed the package of measures to tackle international corporate tax avoidance, which was endorsed by the G20 Finance Ministers in Cairns, Australia. The Ministers agreed on a first set of recommendations to...
We welcome the OECD announcement on OECD BEPS project and deliverables. Today is a landmark day for the international tax world and it is expected that the BEPS project marks its first turning point in the history of international co-operation...
This September is a very challenging and landmark period for the international tax world. The OECD releases its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 Base Erosion and Profit Shifting (BEPS)...
Today, the OECD will have the launch of the first 7 deliverables, together with an official Explanatory Statement, will take place on 16 September 2014. This set of agreed measures will be presented to the G20 Finance Ministers in Cairns...
The Government has decided that a new ‘strict liability’ criminal offence should be introduced for those failing to declare taxable income and gains arising offshore. This statutory presumption of guilt is highly controversial as it means that HMRC will not...
This September will be a very exciting period for the international tax world and it is expected that the BEPS project marks its first turning point in the history of international co-operation on taxation. Pascal Saint-Amans, Director of OECD Centre...
HMRC Direct Recovery of Debt HMRC’s Direct Recovery of Debts (DRD) consultation document was published this week, seeking views on the implementation of the controversial new debt enforcement powers that were announced in the 2014 Budget. The proposed DRD regime...
The EU Savings Directive (2003/48/EC) entered into force on 1 July 2005. Its purpose is to prevent the evasion of taxes on savings income within the EU. The Directive requires Member States to exchange information automatically so as to enable...
On 13th February 2014, the OECD presented their latest weapon in the attack of global tax avoidance. The new standard builds on specific country agreements and 2010 US FATCA provisions to drive greater transparency and disclosure. In essence the standard...
HMRC expects to pass the necessary secondary legislation to activate the information exchange agreements with the Isle of Man, Guernsey, Jersey and Gibraltar as from 31 March 2014 and is consulting on the precise form of the SIs required. This...
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