Tax Investigation
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...
HMRC victorious against Clavis Liberty tax avoidance scheme
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...
HMRC win another EBT case
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...
More Data – HMRC’s key to the Hidden Economy
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...
Happy Birthday! Now report your employer!
The recent publication of a new list of employers who are being ‘Named and Shamed’ for failing to pay the National Minimum Wage does much to instil terror in the hearts of employers everywhere – but, if anything, it also...
BEPS/Brisbane Summit: G20 Helps Restore Fairness to Global Tax System
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...
Life after Amazon, the Modernisation of Tax Ruling Practice in Luxembourg
The European Commission opened an in-depth investigation on 7 October 2014 to examine whether the decision by Luxembourg’s tax authorities with regard to the corporate income tax to be paid by Amazon in Luxembourg comply with the EU rules on state...
European Commission kindles first flames in battle with Amazon
State aid: Commission investigates transfer pricing arrangements on corporate taxation of Amazon in Luxembourg Today, the European Commission announced that it has opened an in-depth investigation to examine whether the decision by Luxembourg's tax authorities with regard to the corporate...
State aid: Next Step on the EU Commission agenda is Gibraltar corporate tax regime and tax rulings practice
State aid: Commission extends in-depth investigation into Gibraltar corporate tax regime to include tax rulings practice The European Commission has a busy agenda in this autumn. On 1 October 2014, the Commission announced that it extended the scope of an...
Alleged aid to Apple and Fiat: Transfer Pricing arrangements of Apple and Fiat are under the EU Commission’s scrutiny
State aid: European Commission publishes non-confidential versions of decisions to open investigations into transfer pricing arrangements on corporate taxation of Apple (Ireland) and Fiat Finance and Trade (Luxembourg) On 30 September 2014 the European Commission has published non-confidential versions of...
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...
National Minimum Wage – First Employers ‘Named and Shamed’
On 8/6/14 the Government published details of the first 25 employers to be ‘named and shamed’ for failing to comply with the NMW legislation – but worse is likely to follow for future offenders. Proving the hours worked Traditionally HMRC,...