The Knowledge Centre

The process of information exchange under the Common Reporting Standard, means that HMRC now receives data from over 100 tax authorities around the world. HMRC can then cross reference this against tax returns received from individuals. Based on the information it has received, HMRC believes that many wealthy individuals are failing to declare tax liabilities relating […]

Schrodinger and his cat Who was Schrodinger? What was special about his cat? And did the FCA really give it a credit licence? “One can even set up quite ridiculous cases,” Schrödinger wrote. “A cat is locked up in a steel chamber, along with the following device …” Feline lovers should look away now. Schrodinger’s […]

EU Law & UK Tax – A ‘High Level’ Analysis Introduction This note is a ‘high level’ analysis of the impact of EU law on the UK tax system and some of the protections that EU law might provide a taxpayer. Overview EU law affects the UK tax system in a number of ways. This […]

What is a Hybrid Partnership? A hybrid partnership is a standard partnership but rather than just having individuals as partners, there is one or more corporate partners (or, in the case of LLPs, ‘members’). Historically this was a popular structure as it allowed businesses to have the ‘best of both worlds.’ As partnerships are transparent […]

Introduction It was back in Autumn Budget 2018 that ex-chancellor Phillip Hammond announced that the UK would take unilateral action to introduce a Digital Services Tax. With a new Chancellor, and a new Prime Minister with a rather close relationship with Mr Trump, it is interesting to see whether this brand new tax will see […]

Transfer of Assets and Income Streams through Partnerships This article aims to help you understand these rules which impose an income tax charge where there is a transfer of assets and income streams through partnerships. As anyone with even the most fleeting interest in the UK tax system will know, the tax code is full […]

Introduction – Profit Fragmentation Rules This has been billed as the new Diverted Profits Tax (“DPT”) for individuals, partners and SMEs. As such, covering the gaps in those original DPT rules. These rules were introduced as part of the Government’s clampdown on international tax avoidance.  The rules were introduced in Finance Act 2019. The target […]

EU tax avoidance directive – DAC6 – HMRC, Hallmarks, CRS & MDR Background Both the Panama & Paradise Papers have acted as a shot in the arm for those calling for greater tax transparency. Initially, the UK looked as though it would act unilaterally (as with the Diverted Profits Tax) as it opened a consultation in […]

Professional Negligence & Tax Advice In recent years, HMRC has made no secret of its stepping up efforts to increase the amount of tax revenue which it generates. The latest edition of its annual report, published in July, underlined its determination to “bear down on avoidance and evasion”. Its success in doing so can be […]