No litigation privilege in advice from accountants on tax structure

In this post we consider the recent decision of the High Court in FRC v Frasers Group Plc, a case in which it was held that advice from accountants on a proposed new tax structure was not protected by litigation privilege, even if litigation over the relevant tax affairs was in reasonable contemplation at the time the advice was given. Read more

DAC 6 Reporting Deferred in the UK

The UK government has today announced that the first reporting deadline under DAC 6 will be deferred for 6 months to allow taxpayers and advisors impacted by COVID-19 additional time to comply with their obligations. The first reports under DAC 6 will now be due by 31 January 2021. Read more

HSF Trust Companies Survey – Tax Insights

We asked trust companies questions about the most significant risk and compliance issues they face. This blogpost, and accompanying podcast, consider the tax issues identified by respondents as most pressing. Read more

Rapid resolution of domicile disputes: be careful what you wish for

In Henkes v HMRC [2020] UKFTT 7645, the First-tier (Tax) Tribunal held that (a) it could (and would) determine the taxpayer’s domicile status when determining an application for the closure of a domicile enquiry and (b) its determination of that issue would be binding in any substantive appeal against a subsequent tax assessment. Read more