Private Client Tax

Dual In The Crown: Considering UK and Swiss Dual Resident Status

Our Private Client Tax Partner Jamie Favell was recently featured in the ePrivate Client annual feature on Switzerland discussing the tax implications of being dual resident in the UK and Switzerland. The full content of his article can be viewed here.  [click here to go to the PDF]   For ease we have also copied the full text into this article as follows: Many high net worth individuals have mobile lives which require their advisors to consider the implications of them spending significant time in more than ... Read More

Mixed Fund Cleansing: Action Required

  To recap, 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 ... Read More

HMRC publishes guidance on cryptoasset investments

HMRC has recently published guidance for UK resident individuals on the potential liability to UK taxes that may arise on receipt or disposal of cryptoassets. The guidance is mainly concerned with cryptoassets held as investments. It is expected that HMRC will publish separate guidance for those trading cryptoassets and for companies but traders can expect to be chargeable to income tax or corporation tax (if a UK taxable company) on profits. Other taxes may apply if an individual receives cryptoassets as ... Read More

HMRC’s Crypto Guidance – New guidance for individuals to be published soon

  THIS ARTICLE HAS BEEN UPDATED ON 21/12/18 - PLEASE FOLLOW THIS LINK   TAP’s governing body the Chartered Institute of Taxation recently attended a meeting of HMRC’s crypto assets roundtable to continue the discussions around the tax treatment of crypto assets. Matters discussed included the current state of the crypto asset market, the Crypto asset Taskforce Report and the new guidance HMRC is preparing. It was confirmed that guidance aimed at individuals will be published shortly, with guidance for businesses following in early 2019. We ... Read More

House of Lords criticises HMRC powers

Yesterday, the House of Lords’ Economic Affairs Committee has published a highly critical report on HMRC powers, describing some as “broad, disproportionate powers without effective taxpayer safeguards”. The report concludes that whilst the Committee is fully supportive of the aim to prevent deliberate evasion and aggressive tax avoidance, some recent powers given to HMRC within legislation “undermine the rule of law” and hinder taxpayers’ access to justice. In recent years HMRC have been given a number of new powers by Government to ... Read More

Probate fee increase dubbed a stealth death tax by the House of Lords

  The UK Government recently published law which, from April 2019, will increase probate fees from £155 to £6,000 for estates valued over £2 million. A Statutory Instrument is a legal mechanism with allows the Government to change a law without that change being fully scrutinised in Parliament. The House of Lords’ Legislation Scrutiny Committee has described this change as a “stealth tax” and an “abuse of power” by the Government. The fees have also been described as a de facto additional inheritance ... Read More

HMRC confirms no trust protection for offshore income gains

In April 2017 significant changes were made to the way in which UK resident but non-UK domiciled individuals (“non-doms”) are taxed in the UK. Broadly, non doms who have been resident in the UK for 15 of the previous 20 tax years are now taxable in the UK on their worldwide income and gains, as well and to inheritance tax on their worldwide assets. The changes to the income tax and capital gains tax rules would, without specific legislation in place, ... Read More

Budget 2018 – summary of key tax announcements

The Chancellor of the Exchequer today announced his final post-Brexit budget. From a personal tax perspective, the Budget contained a number of small changes to existing rules and confirmation of policies already announced but not much new of major significance. As expected, the key announcement in terms of business taxation is the introduction of a Digital Services Tax on very large businesses and partial relief from business rates at the other end of the scale. The key issues are summarised as follows: Rates and ... Read More

HMRC shown red card in referees’ employment taxes case

English football referees have won a First Tier Tribunal case against HMRC’s attempt to classify them as employees rather than self-employed for the purposes of Pay As You Earn (PAYE) and National Insurance Contributions (NICs). The case highlights the complexity that can exist in determining a person’s employment or self-employment status. Whilst a select group of the top English football referees are employed full-time by PGMOL (the Professional Game Match Officials Limited) most referees in professional English football referee in their spare ... Read More

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
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