‘We are delighted to share with you the first edition of the 1 Crown Office Row Tax Newsletter.
In this issue, we bring you a range of important insights and updates from across the tax team covering the ever-changing landscape of tax law. The newsletter covers a broad range of topics across the work we do, covering significant and interesting cases from 2024.’
1 Crown Office Row, 10th December 2024
Source: www.1cor.com
‘The three cases below provide valuable insights into the complexities of customs regulations and the importance of meticulous compliance. They underscore the need for businesses to adopt robust compliance mechanisms to prevent errors and fraud, while also highlighting the importance of a balanced approach in customs enforcement to ensure that penalties are commensurate with the nature and impact of non-compliance.’
33 Bedford Row, 4th December 2024
Source: www.33bedfordrow.co.uk
‘This guide outlines some of the key tax issues to consider when setting up a subsidiary in the UK. It assumes that the subsidiary will be a private company limited by shares, although other legal forms are available.’
OUT-LAW.com, 10th December 2024
Source: www.pinsentmasons.com
‘Former Harry Potter actor Rupert Grint must pay more than £1.8m in tax after losing a legal battle with HM Revenue and Customs. Grint, who played Ron Weasley in the franchise, was ordered to pay the sum in 2019 after HMRC launched an investigation into his tax return from the 2011-12 tax year.’
The Independent, 30th November 2024
Source: www.independent.co.uk
‘HMRC v The Taxpayer (Appellant) and Times Media Limtied and News Group Newspapers Limited and PA Media Tax Policy Associates Limited (Third Parties) [2024] UKUT 00364 (TCC). This case concerns an application for taxpayer anonymity in the Upper Tribunal (Tax and Chancery Chamber). The taxpayer, who had initially appealed against HMRC’s denial of certain tax deductions, sought to keep their identity confidential during the proceedings and in the final decision. This request was opposed by HMRC and several media organizations, including Times Media Limited and News Group Newspapers Limited.’
33 Bedford Row, 22nd November 2024
Source: www.33bedfordrow.co.uk
‘Domicile has been a fundamental basis of jurisdiction in English law including English family law. But it is intrinsically backward-looking, archaic in its concepts, thoroughly unknown or at best misunderstood by the population, differently defined abroad and at odds with many other countries including the EU. With the non-domicile tax status being abolished as announced in the budget in late October 2024, is it not time now to end domicile as a family law basis of jurisdiction? Nationality is a far more straightforward, certain and modern basis.’
Financial Remedies Journal, 11th November 2024
Source: financialremediesjournal.com
‘The Autumn Budget 2024 (“the Budget”) saw history being made as Rachel Reeves, who became our first female Chancellor of the Exchequer, set out arguably the biggest tax changes for a generation, set to raise taxes by £41bn by 2029/30 and said to be part of the Government’s plan to revitalise Britain. In this article, we will summarise the key reforms of the Budget, highlighting those which may be of particular relevance to financial remedy practitioners and their clients.’
Financial Remedies Journal, 1st November 2024
Source: financialremediesjournal.com
‘A group representing 1,400 private schools will press ahead with plans for a legal challenge against the government’s introduction of VAT from January, the BBC can reveal.’
BBC News, 31st October 2024
Source: www.bbc.co.uk
‘The founder of the money transfer service Wise has been fined £350,000 for failing to inform the City regulator that he had failed to pay his taxes.’
The Guardian, 28th October 2024
Source: www.theguardian.com
‘Waqar Shah and Andy Norris analyse the latest decision of the Supreme Court in the case of Professional Game Match Officials Ltd, which has been referred back to the First-tier Tribunal.’
Kingsley Napley Employment Law Blog, 22nd October 2024
Source: www.kingsleynapley.co.uk
‘A independent faith school in Hampshire has launched a legal challenge against the government’s plans to introduce VAT on private school fees.’
BBC News, 21st October 2024
Source: www.bbc.co.uk
‘Wales’ biggest council has agreed to pay £16m to settle a bill over landfill tax dating back 10 years.’
BBC News, 21st September 2024
Source: www.bbc.co.uk
‘The off-payroll working rules, known as IR35, apply where a business engages an individual to provide services off-payroll and through an intermediary – commonly a company referred to as a ‘personal services company’ (PSC). IR35 targets the use of PSCs to avoid employment taxes.’
OUT-LAW.com, 13th September 2024
Source: www.pinsentmasons.com
‘Foreign companies need to have a substantial presence in the UK, including adequate human and technical resources, for their branch to qualify as a “fixed establishment”, a necessary condition for being treated as a member of a value added tax (VAT) group in the UK, a recent ruling has confirmed.’
OUT-LAW.com, 6th September 2024
Source: www.pinsentmasons.com
‘This guide considers the tax implications of using a UK holding company to hold shares in other UK or overseas companies.’
OUT-LAW.com, 9th August 2024
Source: www.pinsentmasons.com
‘Tax deductions were not available for professional fees incurred by an investment company once a decision to sell a business it held had been made, because they were expenses of a capital nature even though they are accepted to have been expenses of management, the UK’s highest court has ruled.’
OUT-LAW.com, 31st July 2024
Source: www.pinsentmasons.com
‘A recent UK Upper Tribunal decision reaffirms the principles governing the application of double tax conventions and provides clarity on the interpretation of treaty provisions aimed at preventing tax avoidance, an expert has said.’
OUT-LAW.com, 19th June 2024
Source: www.pinsentmasons.com
‘The FTT has now handed down its first decision regarding the proper construction of the carried interest provisions at Part III, Ch 5 of the Taxation of Chargeable Gains Act 1992 (TCGA 1992) and the transitional/grandfathering provision at s. 43 (2) Finance (No.2) Act 2015.’
Devereux Chambers, 13th May 2024
Source: www.devereuxchambers.co.uk
‘A recent UK Upper Tribunal decision highlights that as soon as there has been a failure to comply with an information notice, a taxpayer is automatically liable for a fixed penalty, even if the failure is short-lived, and HMRC can move straight to applying for a tax-related penalty, an expert has said.’
OUT-LAW.com, 11th June 2024
Source: www.pinsentmasons.com
‘Angela Rayner has been cleared of criminal wrongdoing over claims she avoided tax on the sale of a home, with the Labour deputy leader criticising what she called the “desperate tactics” of Conservative MPs who urged police to investigate.’
The Guardian, 28th May 2024
Source: www.theguardian.com
© Inner Temple Library 2024