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Oct 3, 2024 | 
taxjournal.com | Johan Barros |Richard Collier |David Whiscombe
Notable/latest case hearings• Applicants in the Post-Prudential Closure Notice Application Group Litigation and another: foreign dividends on portfolio holdings & double tax relief (CA hearing date due 21 January 2025). • A taxpayer: statutory residence test (CA hearing 28 January 2025). • AXA Sun Life plc: overpaid tax – restitution (CA hearing due 15 October). • BAT Industries: FII GLO limitation period (CA hearing scheduled for 13 May 2025).
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Oct 2, 2024 | 
taxjournal.com | Johan Barros |Richard Collier |Chris Etherington |Rebecca Harris
In D Hill and another v HMRC [2024] UKFTT 844 (TC) (16 September) the FTT held that reliance on an adviser was not a reasonable excuse for failing to comply with an information notice and penalties were upheld without mitigation. The FTT decided that neither of the appellants took objectively appropriate steps to consider whether it was reasonable to rely on the advisers and the advice provided.
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Oct 2, 2024 | 
taxjournal.com | Chris Holmes |Martin Codd |Johan Barros |Richard Collier
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Oct 2, 2024 | 
taxjournal.com | Johan Barros |Richard Collier |David Whiscombe
The UK’s proposed non-dom changes were originally hailed as not only removing unfairness in the tax system, but also as a tax-generating measure. In the Labour Party’s election manifesto, it was anticipated the measures would generate £5.23bn by 2028/29, which money was allocated to fund NHS appointments, new scanners, free primary school breakfast clubs and investment in HMRC to reduce tax avoidance.
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Oct 1, 2024 | 
taxjournal.com | Johan Barros |Richard Collier |Chris Etherington |Rebecca Harris
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Oct 1, 2024 | 
taxjournal.com | Jo Crookshank |Gary Barnett |Johan Barros |Richard Collier
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Oct 1, 2024 | 
taxjournal.com | Georgia Hicks |Johan Barros |Richard Collier |Chris Etherington
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Oct 1, 2024 | 
taxjournal.com | Johan Barros |Richard Collier |Chris Etherington |Rebecca Harris
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Oct 1, 2024 | 
taxjournal.com | Johan Barros |Richard Collier |David Whiscombe
Various media outlets have been reporting a potential rethink of the non-dom proposals ahead of the new Government’s first Budget on 30 October 2024 with the Financial Times quoting ‘a government official’ suggesting that while general reform will remain on the table ‘we will be pragmatic not ideological.
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Oct 1, 2024 | 
taxjournal.com | Johan Barros |Richard Collier |Chris Etherington |Rebecca Harris
The UK government has halted changes to the interpretation of assimilated case law that otherwise were to have taken effect from 1 October 2024. The Retained EU Law (Revocation and Reform) Act 2023 (Commencement No 2 and Saving Provisions) (Revocation) Regulations SI 2024/976 revoke the Retained EU Law (Revocation and Reform) Act 2023 (Commencement No 2 and Saving Provisions) Regulations SI 2024/714 with effect from 18 September 2024.
