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Mar 13, 2024 | 
solicitorsjournal.com | Hugh Gunson |Stewart Hey |Rachel Warren
Readers will no doubt be familiar with the cum-ex tax fraud scandal that has been making waves across Europe (see, for example, our recent article The cum-ex scandal explained: the enforcement net widens). There is another related, but different, potential scandal on the horizon, involving another type of trading strategy commonly known as ‘cum-cum’ (Latin for ‘with-with’). The sums involved have been said to dwarf even those at stake in relation to cum-ex.
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Feb 21, 2024 | 
taxjournal.com | Hugh Gunson |Oliver Marre |Sharon Baynham |Andrew Marr
Home >Articles > HMRC v The Taxpayer: balancing the public and private HMRC v The Taxpayer: balancing the public and private © Copyright LexisNexis 2024. All rights reserved. 21 February 2024 Speed read The Upper Tribunal decision in HMRC v The Taxpayer illustrates the difficulties involved in obtaining privacy and/or anonymity orders in tax tribunal proceedings, when balanced against the principle of open justice.
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Feb 19, 2024 | 
lexology.com | Hugh Gunson
At the time of writing, there is less than a week to go until the closing of HMRC’s most recent consultation on the off-payroll working rules (commonly known as “IR35”).
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Feb 2, 2024 | 
solicitorsjournal.com | Hugh Gunson |Rachel Warren |Stewart Hey
The cum-ex scandal has been making headlines for years. As distinct from the parallel cum-cum dividend frauds, the practice involved the trading of shares for the purpose of claiming multiple refunds of the same withholding tax; and the sums involved are huge. However, what started as an issue in Germany, Denmark, Italy and France, is now spilling over into other jurisdictions, including the UK and US.
The sums involved are eye watering.
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Jan 17, 2024 | 
taxjournal.com | David Whiscombe |Andrew Howard |Johan Barros |Hugh Gunson
Reliance on artificial intelligence (AI) is now common practice in the legal profession. Either through smart contracts, analytics or case management software, legal professionals increasingly use machine learning and AI-based tools for the quick, accurate and cost-efficient provision of legal services. However, predictive justice – the use of AI-enabled technologies for predicting outcomes of legal disputes – is a recent development.
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Jan 17, 2024 | 
taxjournal.com | David Whiscombe |Andrew Howard |Johan Barros |Hugh Gunson
HMRC have confirmed that, where Horizon Shortfall Scheme (HSS) top-up payments are not made ‘in good time’ for the recipient to file a self-assessment tax return by 31 January 2024, no late-filing or late-payment penalties (or interest) will be charged. This will also apply where the £300 ‘tax advice grant’ has not been received in good time. HMRC have also set up a dedicated helpline for affected individuals.
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Jan 15, 2024 | 
taxjournal.com | David Whiscombe |Andrew Howard |Johan Barros |Hugh Gunson
Home >Articles > Characterising a single supply following the Court of Appeal’s decision in Gray & Farrar Characterising a single supply following the Court of Appeal’s decision in Gray & Farrar © Copyright LexisNexis 2024. All rights reserved. 15 January 2024 Speed read How is a single complex supply to be characterised for VAT purposes?
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Jan 11, 2024 | 
taxjournal.com | David Whiscombe |Andrew Howard |Johan Barros |Hugh Gunson
MTDHMRC are inviting feedback on a Technical consultation on draft Income Tax (Digital Requirements) (Amendment) Regulations 2024 and associated notices. Closes: 12 January. Multinational Top-up Tax and Domestic Top-up TaxHMRC invites comments on partial draft guidance. Closes: 7 February. Permanent full expensingthe government will be holding working group meetings with interested stakeholders from January 2024 onwards.
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Jan 11, 2024 | 
taxjournal.com | David Whiscombe |Andrew Howard |Johan Barros |Hugh Gunson
Manual Page Comments Theatre Tax Relief Manual Updated: TTR10010 Guidance on theatre tax credit rates now reflects the two-year extension of the temporary higher rates until 31 March 2026. Inheritance Tax Manual Updated: IHTM05092 and IHTM05093 Updated details on the process where an Eik is required to confirmation (Scotland) and what to do if an application for Eik to confirmation is received.
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Jan 10, 2024 | 
taxjournal.com | David Whiscombe |Andrew Howard |Johan Barros |Hugh Gunson
The UK government’s response to the consultation on the VAT treatment of fund management services confirms that the VAT exemption for the management services of funds listed under VATA 1994 Sch 9 Group 5 Items 9 and 10 will remain in place. The consultation confirmed that there is widespread reliance on items 9 and 10, ‘with a strong preference among respondents to continue to rely on a single model based on these items’.
