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
In Mackay v Wesley [2020] EWHC 1215 (Ch), the Claimant, who was instructed by her father to become a trustee of a family trust as part of a tax scheme, failed to obtain from the High Court (1) an order rescinding her appointment as trustee and/or (2) a declaration that she never became a trustee. Read more
In Fowler v HMRC [2020] UKSC 22, the Supreme Court determined that a statutory fiction created by a deeming provision of UK tax law did not affect how the terms of a bilateral tax treaty should be applied. Read more
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
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
This bulletin considers HMRC's updated guidance on the Statutory Residence Test, which extends the "exceptional circumstances disregard" in light of the COVID-19 pandemic. Read more
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
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
