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

The extra-territorial reach of HMRC’s investigatory powers

In R (on the application of Jimenez) v the First-tier Tribunal (Tax Chamber) and HMRC, the Court of Appeal determined that HMRC had power to issue a compulsory information request to an individual outside the UK (for the purpose of checking that individual's tax position). Read more

When can trustees assert privilege?

In this webinar, we tackle some of the tricky issues relating to legal professional privilege that can arise in cross border and regulatory contexts, including tax investigations. Read more