Private Client Tax

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

Inheritance Tax- don’t leave it too late

Forewarned is Forearmed For many people, inheritance tax (IHT) planning is put firmly to the back of their mind and often left too late to leave time for any realistic planning opportunities. There are many basic planning opportunities which should be given due consideration now to help minimise your potential exposure to IHT and to ensure your loved ones receive as much of your hard-earned estate as possible. Do you have an IHT exposure? The IHT nil rate band for any individual is currently £325,000. ... 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

Discovery Assessment for Offshore Non-Compliance

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 ... 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

Playing a Let

Rent-a-room is a tax relief available individuals who let out a room/s in their home whilst occupying the property at the same time, for example to long-term lodgers, students, individuals working away from home during the week, tourists and short-term visitors – such as those visiting London to attend Wimbledon. It was originally introduced in the UK in 1992 by the Government to try and encourage individuals to let out their spare rooms. The individual is not required to own the property ... Read More

Overseas workdays relief – Expat Tax Back

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 ... Read More
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