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Are you ready for the Economic Crime Levy?
On 28 February 2023, HM Treasury published draft regulations, together with an explanatory memorandum, that revise and make further provision for assessment, payment, collection, and enforcement of the Economic Crime Levy (ECL).
Read moreShifting the dial on ESG
For international women's day we have produced a special episode of our Taxing Matters podcast, in which we discuss macro trends in ESG and gender diversity at work, the meso-level changes within organisations and the micro changes on a personal level talking through trends in ESG. Did we lose momentum during Covid? Do we still have the emphasis in the right places? And what can each of us do to shift the dial?
Read moreTax Bites - March 2023
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreCorporate tax update – February 2023
Welcome to the latest edition of our Corporate Tax Update, written by members of RPC's tax team.
Read moreCouldn’t careless? Reasonable care and the role of professional advisers
Whilst taking professional advice will usually mean a taxpayer has taken reasonable care, not taking advice does not necessarily mean a taxpayer has been careless.
Read moreV@ update - February 2023
Welcome to the February 2023 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.
Read moreCustoms and excise quarterly update - February 2023
Welcome to the February 2023 edition of RPC's Customs and Excise Quarterly Update.
Read moreUnravelling the differences between the UK & US tax systems
In this episode of Taxing Matters, we are joined by Alex Jones and Graeme Privett who share their insights and views on how the US and UK are less similar than people might think and how this could lead well-meaning taxpayers into avoidable difficulties.
Read moreTax Bites - February 2023
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreVictory – but at what cost?
From a review of recent costs decisions handed down by the FTT, it is difficult to escape the conclusion that the FTT can be guilty of inconsistency and results-led reasoning when exercising its jurisdiction in relation to costs orders.
Read moreV@ update - January 2023
Welcome to the January 2023 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.
Read moreCorporate tax update - January 2023
Welcome to the latest edition of our Corporate Tax Update, written by members of RPC's tax team.
Read moreWitness Familiarisation
In this episode of Taxing Matters, we demystify what is witness familiarisation and what is permitted by the tax tribunals and the courts with Dr Penny Cooper.
Read moreUK Government’s plans to raise as much as £200m a year from seizing crypto assets at risk without proper investment
Plans by the UK Government to seize as much as £200m a year in crypto assets* will be difficult to implement without significant investment in resources to pursue such seizures, says international law firm RPC.
Read moreTax Bites - December 2022
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreCustoms and excise quarterly update - November 2022
Welcome to the November 2022 edition of RPC's Customs and Excise Quarterly Update. In order to enhance your reading experience, we have adapted the format. We hope you like it
Read moreV@ update - November 2022
Welcome to the November 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.
Read moreAmount seized in forfeiture orders jumps 77% to £191m in past year
The amount of money seized by UK law enforcement agencies, including His Majesty's Revenue and Customs (HMRC), the Serious Fraud Office (SFO) and the National Crime Agency (NCA), has jumped 77% from £108m to £191m in the last year*, says international law firm RPC.
Read moreTax Bites - November 2022
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreTribunal allows taxpayer's appeal and confirms its holding in another company constituted a "structural asset"
Tribunal allows taxpayer's appeal and confirms its holding in another insurance company constituted a "structural asset" for the purpose of section 137, Finance Act 2012.
Read moreV@ update - October 2022
Welcome to the October 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.
Read moreUpper Tribunal agrees with the taxpayer on payments to secure changes to pension arrangements
The Upper Tribunal allowed E.ON's appeal against HMRC's decisions imposing income tax and national insurance contributions to facilitation payments for changes to pension arrangements.
Read moreLack of documentary evidence no bar to proving capital loss claim
Allowing the taxpayers' appeal, the First-tier Tribunal held the Appellant was entitled to claim a capital loss from an earlier tax year to reduce the capital gains tax due on a gain realised by him on the sale of a commercial property because the claim was notified in time, and that inaccuracies in the Appellant's return had not been brought about deliberately.
Read moreHMRC's Ramsay argument fails
HMRC loses capital allowances case as Ramsay argument fails.
Read moreTribunal considers salaried member rules for the first-time and allows taxpayer's appeal in part
Tribunal considers salaried members rules for the first-time allowing taxpayer's appeal in part
Read moreTax Bites - October 2022
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreNew powers proposed to enable law enforcement agencies to seize crypto assets
On 22 September, the UK government introduced The Economic Crime Bill. The Bill contains provisions to make it quicker and easier for law enforcement agencies, such as the National Crime Agency, to seize, freeze and recover cryptoassets used by criminals to launder the proceeds of crime.
Read moreV@ update - September 2022
Welcome to the September 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.
Read moreValuing leasehold interests in trade-related properties using profits method does not involve disaggregation of property value and "transferable goodwill"
Valuing leasehold interests in trade-related properties using profits method does not involve disaggregation of property value and "transferable goodwill".
Read moreRepeal of IR35 reforms
The Chancellor announced at last week's “mini-Budget” that the recent changes to the “off-payroll” working rules (commonly referred to as 'IR35') are going to be reversed, from 6 April 2023.
Read morePurpose-based rules: Have we hit BlackRock-bottom?
In HMRC v BlackRock Holdco 5 LLC [2022] UKUT 199 (TCC), the Upper Tribunal (UT) allowed HMRC’s appeal, holding that the First-tier Tribunal (FTT) was wrong to interpose certain terms (covenants) in loans when conducting its analysis of the counter-factual transaction as between the taxpayer and an unconnected third-party. It held that the FTT was wrong to attribute all of the loan debits arising to the taxpayer's commercial main purpose and should instead have arrived at the opposite conclusion.
Read moreHMRC made to cry a river over SEIS defeat
FTT holds in favour of taxpayer in technical SEIS / EIS relief decision.
Read moreResearch and development tax relief
In this episode of Taxing Matters, we discuss the role of R&D tax relief, how to qualify for the relief, how to stay compliant, some common abuses of the system and some of the recently proposed reforms.
Read moreTribunal upholds HMRC notice transferring debt from managed service company to its former director
Tribunal upholds HMRC notice transferring a debt from a managed service company to its former director.
Read moreHMRC announces latest 'nudge' letter campaign concerning 'Persons of Significant Control' and share disposals
HMRC's Wealthy External Forum has revealed that it is sending nudge letters to people who are recorded as being 'Persons of Significant Control' in unquoted companies.
Read moreTax Bites - September 2022
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreTaxpayer successful in application for permission to rely on expert evidence
Taxpayer successful in application for permission to rely upon expert evidence.
Read moreHMRC prepares for new 'nudge' letter campaign aimed at offshore corporates owning UK property
HMRC are targeting offshore corporates that own UK property and who may not have met all of their UK tax obligations. HMRC have confirmed that they will be launching a new campaign in September 2022.
Read moreV@ update - August 2022
Welcome to the August 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.
Read moreAll settled!
Loan relationship appeal allowed as credit relating to settlement of litigation due to mis-selling of swaps did not arise from related transaction.
Read moreCustoms and excise quarterly update - August 2022
Welcome to the August 2022 edition of RPC's Customs and Excise Quarterly Update.
Read morePermission to appeal not required for successful party to a tax appeal
In dismissing the taxpayer's objection, the Upper Tribunal decided that HMRC, who had won before the First-tier Tribunal need not apply for permission to appeal in order to raise two new arguments in response to the taxpayer's appeal to the Upper Tribunal.
Read moreCapital Gains and Principal Residence Relief: What Makes a House?
Allowing the taxpayers' appeals, the First-tier Tribunal held that, for the purposes of calculating entitlement to Principal Residence Relief under sections 222 and 223 of the Taxation of Chargeable Gains Act 1992, "dwelling-house" did not include the land on which the house was built, and "period of ownership" referred only to the period of ownership of the dwelling-house itself.
Read moreTax Bites - August 2022
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreTax Bites - July 2022
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreTribunal confirms discovery assessment was invalid as enquiry window was still open
Tribunal allows taxpayer's appeal confirming that a discovery assessment raised under section 29 Taxes Management Act 1970, was invalid as the enquiry window was still open.
Read moreHMRC investigating hundreds of UK customers of Puerto Rico-based Euro Pacific Bank
HMRC investigating hundreds of UK customers of Puerto Rico-based Euro Pacific Bank.
Read moreV@ update - July 2022
Welcome to the July 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.
Read moreAgent was careless notwithstanding white space disclosure
White space disclosure on tax returns not a defence against claim of carelessness, as FTT upholds discovery assessments.
Read moreHMRC fails to discharge burden of proof in appeal against personal liability notices
Taxpayer win in case where MTIC fraud alleged in relation to zero-rating of supplies for VAT.
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