Bella Figura, advice and carelessness

Bella Figura, advice and carelessness

by | May 12, 2020 | Update

Establishing reasonable excuse and reasonable care in cases where clients have taken advice can be tricky and HMRC can be resistant. The recent decision of the Upper Tribunal in Bella Figura should help. HMRC officers seem increasingly reluctant to accept that clients...
Loan charge draft legislation and guidance

Loan charge draft legislation and guidance

by | Mar 24, 2020 | Update

The draft legislation and some associated guidance following the Morse report were published as part of the budget package. The guidance and legislation which has been published is (unsurprisingly for those who have been following this closely) complicated. At a high...
Confusion continues on loan charge changes

Confusion continues on loan charge changes

by | May 21, 2019 | Update

A high degree of uncertainty remains for Individuals who have received loans from EBT’s despite most of the recommendation of the loan charge review led by Sir Amyas Morse being accepted. The central plank of the recommendations was that loans made before 9 December...
Offshore Enabler Penalties

Offshore Enabler Penalties

by | May 21, 2019 | Update

Penalties for enablers of offshore non-compliance introduced in Finance Act 2016 have now been effective for more than 2 years. The penalties are potentially very wide-ranging, applying in any circumstances where a person ‘enables’ offshore non-compliance. Enabling...
HMRC and Discovery Assessments

HMRC and Discovery Assessments

by | May 21, 2019 | Newsletter, Update

HMRC’s power to raise discovery assessments continues to be the subject of litigation on a number of fronts. Most recently, both the courts and tribunals have held that discovery assessments were invalid on the basis of ‘staleness’, because they were not made on the...