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Latest updates and insights from our experts in tax dispute resolution.
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...
GAAR Panel Ruling– can we get rid of Part 7A now (please)?
By Jon Preshaw This GAAR panel ruling can’t have been a surprise to anyone. However, I can’t really see any basis on which the transactions could realistically have escaped Part 7A anyway. The GAAR appears to have been applied in advance of a 'normal' assessment and...
Tribunal criticises HMRC – Is there a reasonable excuse?
By Jon Preshaw Two recent cases decided last month, Belloul [2020] UKFTT 312 (TC) and Jacques [2020] UKFTT 311 (TC) contain some really helpful material for those dealing with tax disputes. Both cases form part of what is becoming an ongoing series dealing with High...
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)...