Danish WHT fraud claim dismissed

The High Court has dismissed a claim by the Danish tax authorities (against more than 100 defendants) that it was wrongly induced to refund more than £1bn of tax.  It did so based on the established principle that English courts will not enforce foreign revenue laws.  Unless reversed, the decision will cast doubt on the ability of other tax authorities to proceed with cum/ex fraud claims in the High Court. Read more

Latest thinking from HMRC on offshore compliance

Within the framework of its "No Safe Havens" tax compliance strategy, HMRC has published two discussion papers concerning aspects of the administration of "offshore" or "international" tax.  You can read more about both papers in this blog post. 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