-
Apr 23, 2024 | 
lexology.com | Tom Gilliver
In the spirit of adventure, or my sapless version of it, I asked ChatGPT 3.5 to propose some puns to deploy in the title of this post. The results ranged from the dull to the surreal. (And some results were both dull and surreal… “Between a Rock and a Tax Place” …?!)Hence my resorting to a hand-crafted title. “Firm Foundations”: it conveys the sense of relief and solidity I felt when reading Lady Justice Falk’s leading judgment in the BlackRock case.
-
Jan 17, 2024 | 
lexology.com | Tom Gilliver
Having introduced more than twenty brand-new taxes since the turn of the millennium — at a rate of roughly one new tax per year — did the UK government really announce yesterday the demise of the diverted profits tax (DPT) before it has reached its tenth birthday?
-
Sep 7, 2023 | 
taxjournal.com | David Whiscombe |Andrew Levene |Carrie Rutland |Tom Gilliver
Insurance companies – structural assetsHMRC consultation on draft regulations: The Insurance Companies (“The Long-term Business Fixed Capital”) Regulations 2023 on how to specify which assets are to be treated as structural assets of an insurance company’s long-term business. This is significant because the income and gains from structural assets are excluded from trading profits.
-
Sep 7, 2023 | 
taxjournal.com | David Whiscombe |Andrew Levene |Carrie Rutland |Tom Gilliver
The facts were simple enough. Mr and Mrs England ([2023] UKFTT 313 (TC), as reported in Tax Journal, 14 April 2023) had borrowed money from their company through having overdrawn directors’ loan accounts. The company became insolvent and the liquidator, apparently recognising the impossibility of recovering the full amount of the debt, did a deal.
-
Sep 7, 2023 | 
taxjournal.com | David Whiscombe |Andrew Levene |Carrie Rutland |Tom Gilliver
The tracker is split into three parts: • cases subject to an appeal which contains those cases that are currently subject to an appeal • cases potentially subject to an appeal which contains those cases that have received judgments and could still appeal these decisions • finalised tax cases which contains those cases that are no longer subject to an appeal Cases subject to an appeal This section of the tracker shows those cases that are currently subject to an appeal. Names of parties Court...
-
Sep 7, 2023 | 
taxjournal.com | David Whiscombe |Andrew Levene |Carrie Rutland |Tom Gilliver
If we imagine a Venn diagram of two overlapping circles, A and B, and call the overlapping area C, what can we say about the individual areas? Quite clearly, we can say that C forms part of both A and B. But what about the relationship between A and B? Does the partial overlap mean that one forms part of the other?
-
Sep 7, 2023 | 
taxjournal.com | David Whiscombe |Andrew Levene |Carrie Rutland |Tom Gilliver
Weekly roundup of HMRC manual changes – 11 September 2023This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors. Direct taxes Manual Page Comments Corporate Finance Manual New: CFM99030 New guidance on which entities can be a ‘relevant entity’ for the purposes of TIOPA 2010 s474 in the context of various structures involving Jersey Property Unit Trusts (JPUTs) and partnerships including examples.
-
Sep 6, 2023 | 
taxjournal.com | Andrew Levene |Carrie Rutland |Tom Gilliver |Anastasia Nourescu
Home >Articles > HMRC reminder of duty to notify
HMRC reminder of duty to notify
6 September 2023
In its stakeholder digest (31 August 2023), HMRC reminds taxpayers of the duty to notify a liability to income tax or capital gains tax for the tax year 2022/23 by 5 October 2023 (i.e. by six months after the end of the tax year).
-
Sep 6, 2023 | 
taxjournal.com | Andrew Levene |Carrie Rutland |Tom Gilliver |Anastasia Nourescu
Home >Articles > Standard for Agents updated
Standard for Agents updated
6 September 2023
In an update to its Standard for Agents, HMRC has confirmed its policy on the treatment of assignments of income tax repayments to agents.
-
Sep 6, 2023 | 
taxjournal.com | Andrew Levene |Carrie Rutland |Tom Gilliver |Anastasia Nourescu
Home >Articles > New customs rules for Northern Ireland
New customs rules for Northern Ireland
6 September 2023
The Customs (Northern Ireland) (EU Exit) (Amendment) Regulations, SI 2023/958 update the UK customs duty rules for goods which are moved between Great Britain and Northern Ireland, based on a new wider definition of whether goods are ‘at risk’ of entering the EU.
