• Blog

    You’re Winding Me Up!

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    Phoenix from the flames In 2016, new rules were introduced to stop a type of “phoenixism”. Not the old sort that really got HMRC’s goat where someone would pay all their debtors but HMRC and then brazenly put their company down only to start trading again (often with a slightly different name). The 2016 rules […]

  • Blog

    Judicial review applications against HMRC – 1 November 2018

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    The past couple of years has seen a noticeable increase in the number of Judicial Review (JR) applications being made against HMRC. The majority of these have been in relation to HMRC using its new powers to issue the various types of notices to enforce payment ahead of a taxpayer’s case being heard by the Tribunal. This article looks at some of the leading applications and how the Courts are cutting HMRC a lot of slack when it comes to their actions.

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    Just a thought… – 1 November 2018

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    The news that Marcelo, the Real Madrid footballer, pleaded guilty to defrauding the Spanish state of €490,000 and received a fine of €750,000 and a suspended jail sentence of four months won’t come as a surprise to those that have been following the Spanish Tax Administration’s (AEAT) raid on footballers over recent years. Like many before him, Marcelo had used a non-Spanish company to exploit his image rights with the income not being taxable in Spain.

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    Panasonic to Relocate HQ from U.K. — over Brexit Tax Fears? – 24 September 2018

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    Whether you approve of him or not, it is difficult to refute President Trump’s assertion that we live in an era where “fake news” abounds.

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    Legal challenge to two UK reliefs: another EU uncertainty – 6 September 2018

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    Unlike the many uncertainties people and businesses face over Brexit, the EU caused another one in July that will not be solved by canny negotiations between Michel Barnier and Dominic Raab (assuming that he is still the UK’s negotiator when you are reading this). In another twist, this one may be of benefit to UK taxpayers, while the EU Commission gets to tweak the tail of UK officialdom.

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    Dutch Railway Avoids Corporation Tax through Irish Entity – 25 June 2018

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    Ireland is well known globally as a leading jurisdiction for aviation finance and leasing structures. However, its low headline rate of corporation tax and generous capital allowances have made it equally attractive for the national railway operators and franchises of various countries including the Netherlands, France and Russia.

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