HMRC Fail in Toothless Attack
Readers of our blogs will know we are always interested in cases analysing the extent of HMRC powers and how they should be used. The recent case of Raymond Tooth and the Commissioners for Her …
Worldwide Disclosure Facility – Last Chance to Disclose?
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Disclosure HMRC HMRC Investigations Capital Gains Tax Income tax Eaves and Co Inheritance TaxHMRC have announced the Worldwide Disclosure Facility (WDF) the latest in a long line of disclosure facilities designed to encourage taxpayers to come forward to disclose previously unreported offshore tax liabilities. Unlike its predecessors, the …
Bayliss – HMRC Seek Extra Penalties From Failed Avoidance Scheme
Another week and another case involving a failed tax avoidance scheme. This time, perhaps more worryingly, HMRC were arguing that the return was submitted fraudulently or negligently by the taxpayer and therefore sought the extra …
Beware New Rules on Liquidations – HMRC Refuse to Give Clearance
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Anti Avoidance HMRC Tax Planning Capital Gains Tax Income tax Company Restructuring Entrepreneurs' Relief Close CompaniesAs you may be aware, new rules are being introduced with effect from April 2016 as part of the Finance Act 2016. These relate to distributions in a winding-up/liquidation and are designed to target certain …
Entrepreneurs’ relief – What is an ordinary share?
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HMRC Tax Planning Capital Gains Tax Sale of Company Entrepreneurs' Relief Eaves and Co Tribunal CasesWe have written in previous blogs about the need to take care over Entrepreneurs’ relief (ER) and preference shares (see Entrepreneurs’ Relief – 5% Test and Preference Shares) and a recent case heard by the …