Emma Chamberlain’s article in Tax Journal 28 Feb 2020 postulates the issue of how to reform IHT.   She believes it needs wholesale reform and in particular tackle issues such as gifts from those with no nexus to the UK. Don’t you think they might be paying tax at home? However, I have three major issues

The UK has ratified the UK / Gibraltar Double Tax Treaty which will therefore come into effect for UK tax purposes, on 1st March 2020 for UK withholding taxes, 1st April for corporation tax and 6th April for the purposes of income tax and capital gains tax. The obvious and immediate benefit is the elimination

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