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 ...
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 ...
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 ...
The government has announced its plans to introduce new legislation which will more than double the retrospective time limit during which HMRC can investigate non-payment of income tax, capital gains tax and inheritance tax from offshore accounts where there is “non-deliberate offshore non-compliance”.
Currently, a discovery assessment can be raised up to four years after the end of the tax year in question, which can be extended to six years if HMRC can demonstrate carelessness has been involved. The proposals ...
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 ...
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 ...
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 ...
Overseas Workdays Relief (OWDR) is a valuable tax relief available to non-UK domiciled taxpayers, which exempts employment earnings relating to duties performed overseas from a charge to UK tax provided certain conditions are met.
If implemented correctly and in the right circumstances the relief can generate very big UK tax repayments.
To be eligible for this relief, an individual is required to:
• Be UK tax resident in the tax year following three consecutive tax years of non-UK tax residence;
• be domiciled outside the ...
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 ...
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 ...