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

Headlines Draft legislation for the new RPDT has been published. Applies to IAS groups which exceed £25m of profits from residential development. Wide scope of activities, but narrow scope of residential e.g. care homes are not included. There is a temporary increase in all NIC rates for 1.25% for 2022/2023. For 2023/2024 onwards, a new

I recently took part in a webinar hosted by the Great Britain-Cyprus Business Association. My presentation was titled ‘Inbound to the UK in 2011 compared to post Brexit 2021 and what is coming in 2022’. It can be viewed at 14:10. Download presentation