Offshore companies with UK property – update

Offshore companies with UK property – update

HMRC have confirmed that they will be undertaking a campaign to address non-compliance with UK tax legislation by companies established outside the UK which hold UK property.   There are two types of letters which HMRC will be issuing – A letter which is...
HMRC nudge letters

HMRC nudge letters

HMRC will shortly begin issuing letters to non-UK companies which own UK property. There will be two types of letter – Letters to companies which may be subject to tax as non-resident landlords or subject to tax under the ATED regime. HMRC also note that such income...
Loan charge guidance – the fog clears (a bit)

Loan charge guidance – the fog clears (a bit)

By Jon Preshaw HMRC have now published guidance on the implications of the Finance Act 2020 changes for ongoing disputes and settlement discussions. As ever, there are a few steps forward and a few steps back. There’s also lots to do before the (now absolutely fixed)...