This browser is not actively supported anymore. For the best passle experience, we strongly recommend you upgrade your browser.
43 results for: hmrc
post featured image

The UK has a system which requires any company paying “yearly” UK-source interest to a non-UK resident to withhold income tax from that...

post featured image

HMRC v Sukhdev Mattu [2021] UKUT 0245 (TCC) is a recent application by HMRC to apply a tax-related penalty on Mr Mattu for alleged...

post featured image

The Court of Appeal has now handed down judgment in the long-running Fisher litigation, over-turning the Upper Tribunal’s earlier decision

post featured image

The location (or situs) of a crypto asset can be important for a number of reasons. If you are making a will, it can impact on the terms...

post featured image

Only a year ago, the case of Graham v Lynch [2020] EWHC 986 indicated that the courts may be inclined to exercise their powers to set...

post featured image

Rebutting HMRC’s desire to stretch section 29 TMA 1970 still further, the Upper Tier Tribunal (UTT) has recently held that HMRC cannot...

post featured image

A family investment company (FIC) is a vehicle which has increasingly been used as a way not only of holding family assets, but also...

post featured image

In the recent case of Murphy v HMRC, Chamberlain J agreed with HMRC’s interpretation of extra-statutory concession B18. He found that UK...

post featured image

On 20 July 2021, the government published draft legislation for the Finance Bill 2021-2022, consultations, and other documents (L-Day)....

post featured image

This is the question which HMRC asked itself, 12 wealthy individuals and 25 agents of wealthy individuals, in a recently published report

post featured image

Tax practitioners dealing with motive-driven tax reliefs, exemptions or anti-avoidance rules can get caught in seemingly futile debates...

post featured image

An old saying goes “put not your trust in money; put your money in trust”. Is this still true when so many trusts now need to be...

post featured image

The decision by the United Kingdom Supreme Court in HMRC v Tooth published on Friday is notable for rejecting the existence of staleness...

post featured image

So-called "discovery assessments" have featured in the UK tax system since at least 1803, but the concept continues to evolve.

What is a...

post featured image

I wrote last year about a proposal that all large businesses be required to notify HMRC in advance if they are taking a tax position that...

post featured image

It has been revealed that last year HMRC imposed a record fine of £23,828,092 on a money services business for anti-money laundering...