Guy Bud

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Articles

R&D tax dispute stresses the importance of providing the right evidence

Sep 18, 2024 | lexology.com | Matthew Greene |Guy Bud

In an article first published by Taxation on 2 September 2024, Matthew Greene and Guy Bud consider the lessons on providing the right evidence that can be learnt from a dispute between software company Get Onbord and HMRC. It is not so long ago that research and development (R&D) disputes were relatively uncommon, certainly in the First-tier Tribunal (FTT). This has changed significantly over the last decade.
Wrong kind of interest? Burlington and double tax treaty anti-abuse

Jul 8, 2024 | lexology.com | Guy Bud |Matthew Greene

In an article first published by International Tax Review, Matthew Greene (Partner) and Guy Bud (Associate Barrister) claim that The UK Upper Tribunal’s pragmatic approach to anti-abuse provisions will be welcomed by the secondary debt market. Double tax treaties are a fundamental part of the international tax landscape. As practitioners will be aware, they can sometimes produce results which at least one of the contracting states does not like.
Employing contractors could get less risky after IR35 rule changes

Mar 15, 2024 | lexology.com | Guy Bud |Matthew Greene

In April, changes to off-payroll or IR35 legislation will address the risks of overpayments to HMRC through incorrect worker status determinations. Writing for Personnel Today, Matthew Greene and Guy Bud explained how the changes could make employing contractors less risky for businesses. New rules that come into force from April 2024 could have a major impact on medium and large corporates who engage workers via so-called personal service companies.
IR35 rules change: Employing contractors could get less risky

Mar 13, 2024 | personneltoday.com | Matthew Greene |Guy Bud

In April, IR35 rules change to address the risks of overpayments to HMRC through incorrect worker status determiniations. Matthew Greene and Guy Bud explain how the changes could make employing contractors less risky for businesses. New rules that come into force from April 2024 could have a major impact on medium and large corporates who engage workers via so-called personal service companies.
HMRC launches a call for evidence on the future of tax investigations and penalties

Mar 4, 2024 | lexology.com | Matthew Greene |Guy Bud

HMRC’s “call for evidence” on opened on 15 February 2024 and has raised more than a few eyebrows among tax practitioners. Partner Matthew Greene and associate barrister Guy Bud examine the update in HMRC’s Tax Administration Framework Review. It is no secret HMRC has been dissatisfied about the scope of its investigative powers for some time. This is perhaps surprising given that HMRC’s powers have generally increased over the last decade or so.
Legal analysis: UK tax case may have wider implications for drillers

Feb 16, 2024 | offshore-mag.com | Anastasia Nourescu |Guy Bud

Anastasia Nourescu * Stewarts Guy Bud * StewartsIn the UK, oil and gas contractors are subject to a special corporation tax regime. Given that almost all UK oil comes from offshore fields, the rules are relevant to many oil and gas operators. However, the law is not always clear, and the limited guidance and court decisions do not cover every scenario that comes up in practice.
HMRC’s assessment powers: key considerations

Feb 7, 2024 | taxjournal.com | Matthew H. Greene |Guy Bud |David SMith |David Smith |Richard Johnson

Home >Articles > HMRC’s assessment powers: key considerations HMRC’s assessment powers: key considerations © Copyright LexisNexis 2024. All rights reserved. 7 February 2024 Speed read HMRC’s assessment powers vary depending on the tax at issue but there are common themes.
How will HNWs be impacted by HMRC’s new ‘side hustle’ crackdown?

Jan 30, 2024 | lexology.com | Matthew Greene |Guy Bud

In January 2024, HMRC announced it was beginning a new crackdown on individuals selling goods on digital platforms such as Airbnb, eBay and Vinted. This was a change in the tax collector’s information gathering powers, rather than in the law, but the news attracted widespread concern including among high-net worth individuals who use these platforms. What is HMRC’s side hustle tax change? There has been a lot of discussion of the new “side hustle tax”.
Court of Appeal loss for Dolphin Drilling in appeal on taxation of oil contractor activities

Jan 18, 2024 | lexology.com | Anastasia Nourescu |Guy Bud

HMRC has been successful in an appeal involving Dolphin Drilling Ltd (“Dolphin”) in relation to the deductibility of vessel hiring costs when calculating profits for ring-fenced corporation tax. The Court of Appeal has clarified the meaning of the word “incidental” in the context of the oil contractor activities rules, which is likely to be of interest to offshore oil operators as well as practitioners dealing with other areas of tax law.
Court of Appeal hears case on taxation of oil contractor activities

Dec 5, 2023 | lexology.com | Guy Bud |Anastasia Nourescu

On 14 December, the Court of Appeal is due to hear HMRC’s appeal against the decisions of the tax tribunals to allow Dolphin Drilling Limited (“Dolphin”) to make full deductions for vessel hiring costs when calculating its profits for ring-fenced corporation tax. Although the facts of the case are quite unusual, the decision will be widely anticipated by those in the offshore oil and gas sector. It will also interest others working in areas of tax law much further afield.