Archives by: Jamie Favell

HMRC’s Requirement to Correct Offshore Tax Irregularities

As previously highlighted, higher HMRC penalties take effect from 1 October this year in relation to ‘offshore’ tax matters. The new regime, known as ‘requirement to correct’ (RTC), imposes some very penal charges where UK tax is found to be underpaid in connection with a jurisdiction outside the UK. That said, to put this in context, where a tax liability is found to be payable in connection with a ‘non-UK’ matter, the default penalty under RTC is 200% of the tax due, and ... Read More

2017 UK–Belarus Double Taxation Convention enters into force

The 2017 UK–Belarus Double Taxation Convention, signed on 26 September 2017, entered into force on 27 July 2018. The Convention takes effect in the UK for: •taxes withheld at source for amounts paid or credited on or after 1 October 2018; •income tax and capital gains tax for any year of assessment beginning on or after 6 April 2019; and •corporation tax for any financial year beginning on or after 1 April 2019. It takes effect in Belarus for: •taxes withheld at source on income derived or ... Read More

Who has a requirement to correct?

It has been well publicised by ourselves, the press and HMRC that the ‘requirement to correct tax due on offshore assets’ ("RTC") needs to be considered and appropriate action taken as necessary before 30 September 2018. HMRC's guidance provides the following detail on when they suggest non-complicance will occur and RTC aaplies: "Offshore non-compliance occurs when there is tax owed to HMRC as a result of tax non-compliance and that non-compliance involves either an offshore matter or an offshore transfer. The tax non-compliance involves ... Read More

Requirement to Correct Offshore Tax Discrepancies

A new punitive offshore penalty regime now applies respect of tax liabilities arising from offshore tax matters. Taxpayers have been given a final ‘opportunity’ to correct any errors for tax years 2016/17 and earlier before 30 September 2018. This opportunity is the ‘Requirement to Correct’ (“RTC”) and any undisclosed offshore tax matters will face a standard eye-watering 200% penalty after that date. The penalty can be reduced to 100% in certain cases. HMRC have made it clear they will target taxpayers using information they ... Read More

Visa Go Go!

It has been reported in the papers that there has been a sharp rise in applications for the UK’s £2M Tier 1 (Investor) Visa. Often referred to as the “Golden VISA” this allows individuals from outside of the EU to come to the UK for 40 months, with an option to extend for a further 2 years. In exchange for the Investor Visa, the applicant must invest £2,000,000 or more in UK government bonds, share capital or loan capital in active and ... Read More

Game, Set & Tax

This year’s Wimbledon winner will net a cool £2.25M in prize money. Not bad for spending a few weeks in the London sun and playing some tennis! But that’s just the cream on the strawberry as they say in SW19… The games stars could be earning endorsement income and bonuses ranging from $5-$30M a year too. Those deals could be in place for endorsing racquets, apparel, watches (usually Swiss!) or for wearing logo'd patches of brands all of who want TV and print ... Read More

Tax Dual Resident : being tax resident in two places at the same time

It is becoming more and more common for expat workers to commute from their home country to another country where they spend their working week. This blog post focuses on how to manage this dual resident situation where the two countries in question have a Double Tax Agreement (‘DTA’) in place. We have a lot of clients, for example, who are resident in the UK and Switzerland, Spain, Germany or the Netherlands. All of whom have a comprehensive DTA in place with the ... Read More

EBTs, Contractor Loans and HMRCs Settlement Offer

Freelance workers must declare any tax-avoidance schemes they have used by 30 September or face punitive penalties. HMRC are targeting 000’s of contractors who were paid by via loans from Employee Benefit Trusts and similar arrangements going back to 1999. HMRCs view is that these arrangements were artificial and are disguised remuneration which should be subject to income tax. It’s important that those affected come forward to settle with HMRC and avoid a loan charge on top of demands for repayment. This would be a nasty sting ... Read More

Requirement to Correct : Cleaning up any offshore tax issues

Finance (No. 2) Act 2017 introduced new Requirement to Correct (RTC) legislation which is targeted at non-complicance in respect of offshore tax matters. Taxpayers who know or suspect that they have unpaid tax relating to overseas assets, income or activities need to act before the 30 September 2018 deadline. Failure to take corrective action will result in much higher penalties being applied for their non-compliance. From 1 October 2018 the minimum penalty will be 100% of the tax owed, but ... Read More

Non-Dom Tax Planning Update

If you are a non-dom living in the UK, certain tax residency milestones can impact your tax status. A £30,000 charge applies to access the remittance basis for those who have been resident in the UK for some part of at least 7 out of the previous 9 tax years. This ‘remittance basis charge’ increases to £60,000 for individuals who have been UK resident in at least 12 of the previous 14 tax years. Since 6 April 2017, a non-dom who has ... Read More
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