Regarding sanctions against Russia,[1] from 10th May 2022 the following will become illegal:[2] to provide a registered office, business or administrative address as well as management services, or to arrange for another person to act as a trustee, nominee shareholder, director, secretary or a similar position, for a trust or similar legal arrangement for any natural

14 March 2022 John Sandeman,  Business Assets & International, HMRC, 8th  Floor, 14 Westfield Avenue, London, NE98 1ZZ BY email to mandatorydisclosure.rules@hmrc.gov.uk Dear Sir, Mandatory Disclosure Rules[1] Consultation Publication date: 30 November 2021 Response of Caesium International LLP We are aware that many respondents will cover many of the issues arising from the consultation. We

Executive Summary The title of this call for evidence, like some of the questions is ill-expressed or thought out.  The words “non-paying” is otiose. Almost all the questions assume that the subject matter, e.g. holding non-UK assets, or intangibles etc is a factor in tax not being paid to HMRC. Yet there is no evidence

This is a question which people are now asking or have been asking, since the court decision in Hannover[1].   It is understood the case is awaiting a date in the courts for the taxpayer’s appeal against the decision of the First-tier Tribunal (FTT). In that case the special purpose vehicle (SPV) was a Guernsey Property

UK withholding tax on interest Hargreaves Property Holdings Ltd [2021] TC 08310 Key points – UK source income, where is the value coming from to repay the debt? Annual interest- all circumstances including purpose, i.e. whether a long-term investment or not. Complex tax scheme, where one of HMRC’s arguments was that interest was yearly and

Euromoney Institutional Investor plc [2021] TC 08046 Key point – even if part of the scheme is blatant tax avoidance, the application must look at the scheme as a whole and not in bits In brief a straightforward application for clearance that s137 should not prevent s135 from applying in respect of an arm’s length

Have you ever worried whether your charity meets the public interest test; one which trustees must report upon in their Annual Return (TAR)? Or are you looking for an independent trustee for your SSIP? Or perhaps you have a family trust with difficult decisions to make? Or maybe a trade body which needs guidance and

In April 2022 the UK QAHC regime comes into place. This type of company must be diversely held as opposed to closely held. Its tax effect is very similar to the foreign branch election for trading companies, but with the difference that closely held trading companies can make a foreign branch election whereas a QAHC

With immediate effect UK residents and non-UK residents will have 60 days in which to file a CGT return on the disposal of residential property, rather than the previous 30 days. With effect from 1st April 2022 A new levy (another word for tax but not using the word “tax”) is to be imposed to