Once upon a time, Christmas meant lots of Anton Berg chocolates, Lindt & Sprungli chocolates, lots with alcohol in them all from the confectionery department of a well-known West End store. In particular, Lindt made stengeli (Swiss German for baton) which were little hollow chocolate batons, with a crystallised inner case and kirsch brandy inside

On 15 October 2019, the text of a new comprehensive double tax treaty (DTT) between the UK and Gibraltar was released (the Treaty).  The Crown Dependencies (CD) (Jersey, Guernsey and the Isle of Man) have had treaties with the UK for a number of years, and these were replaced with comprehensive treaties in 2018 (with

EU rules, red tape, bureaucracy, etc., but let’s remind ourselves of some basic facts. For the last 4,000 years[1], Britain has been trading with others from overseas.  Amber from the Baltic, figs and wine from France in return for metals, stone etc.   Things have changed a lot in the last 4,000 years, and all we

Headlines Companies with interest expense over £2m pa need to make PIE election and remove other sources of income. All companies must review their financial arrangements for the applicability of the many UK restrictions for deductibility of interest. Companies will be able to claim land remediation relief and utilise group relief with other corporation taxpayers.

There are many reasons why Mr Gove demonstrates his cluelessness, but the suggestion to abolish VAT and replace it with a sales tax is so unintelligent, retrograde and moronic as to be incredible. There is a reason that only the USA insists on sales taxes, apart from having very small brains, and that is it

Please see https://www.linkedin.com/feed/update/urn:li:activity:6527125628951494656. This case had a normal pre-sale reorganisation, a sale of “shares” (see s.75C(1) FA 2003 – as the judge found this as the first step then surely it should be disregarded?) and a normal post sale reorganisation driven by German regulatory requirements. Any advised Vendor would do a bona fide pre-sale reorg.

Nothing in this paper is to be regarded as advice, let alone advice on investment in securities; it is the author’s personal opinion and to assist in the explanation of the topic. Just before Christmas 2018, HMRC dropped their views on the taxation of individuals investing in cryptoassets on to the internet[1].  It caught many

NB this is a review of the first draft published on 14th November 2018.  Small changes have been made since, for example the “20XX” date is now 2022. Executive Summary This is not Brexit. Certainly not on 29 March 2019. Statements from the PM in the media to that effect are being economical with the

1. General Points 1.1. Given the outcomes of previous reviews and OTS reports, one cannot help but see this is another attempt to increase taxes in the name of “fairness”. We would challenge HMRC to buck the trend and confound the cynics. 1.2. The document is misguided in some of its fundamentals. 1.2.1. First, this

Whilst there are still many important issues to resolve in the agreement for the UK’s withdrawal from the EU, it is fairly clear given statements made by M. Barnier that there is very little prospect of the UK keeping the benefit of EU tax measures, such as the Royalties and Interest Directive and the Parent