Matthew Greene

Cleveland, Riyadh

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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.
What does it take to prove an R&D tax relief claim?

Jul 22, 2024 | lexology.com | Matthew Greene

Many UK companies that have submitted claims for Research and Development (R&D) tax relief have been exasperated by HMRC’s approach to their claims. The First-tier Tribunal’s decision and comments in the recent case of Get Onbord Limited [2024] UKFTT 617 (TC) provide a welcome dash of common sense and cause for optimism that HMRC’s approach to R&D claims may prove less intransigent from now on.
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.
What does the abolition of non-dom status mean for high net worths in the UK?

Mar 7, 2024 | lexology.com | David Pickstone |Matthew Greene

In the 2024 spring Budget, Chancellor Jeremy Hunt announced that non-dom tax status would be “abolished” as of April 2025, replaced by a “modern, simpler and fairer” taxation system. David Pickstone and Matt Greene, partners in our Tax Litigation and Resolution team, explain what these changes may mean for affected individuals and for HMRC.
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.
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”.