Law, Interpretation and Common Sense
Here is a conundrum. A long, long time ago … in a galaxy far, far away (a.k.a. York, England 1981) I was a newly created Inspector of Taxes. I was taught that the tax rules …
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 …
Farce: Manchester United and HM Treasury
Hello, 1) Sorry for the informality of the greeting but if you were doing a training exercise on fake bombs and security, would you not (at least) count up the number of imitations you had …
What happens when laws collide?
Here is a case which emphasises points about pre-planning for tax purposes. It may also be one for legal philosophers! In the recent case of G4S Cash Solutions (UK) Ltd v CIR, the Courts followed …
Panama Leak – Offshore Disclosures
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Disclosure HMRC Investigations Penalties Income tax UK Swiss Tax Treaty Contractual Disclosure Facility Isle of Man Disclosure FacilityAs you will have likely heard in the press recently, a leak of confidential documents from Panamanian law firm Mossack Fonseca has brought fresh attention to offshore tax evasion through the use of tax havens. …