Matthew Fleming and Chris Leigh (KPMG) examine the legal developments that strengthen HMRC’s ability to tackle cross-border non-compliance.
In most cases there will be little question as to whether the actions of both Parliament and the UK courts respect the basic principles of national sovereignty and the territorial limits of UK law. This is especially true in the world of tax yet recent years have seen an increasing boldness from both Parliament and the courts.
The latest development on extra-territoriality in the tax sphere has come from two unrelated sources:
a decision of the Court of Appeal in R (oao Jimenez) v The First-tier Tribunal [2019] EWCA Civ 51 (Jimenez); and
unrelated legislation from Parliament in the form of the Crime (Overseas Production Orders) Act (COPO) 2019 which received royal assent on 12 February 2019 but which has not yet been brought into force (the Act will instead come into force...
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Matthew Fleming and Chris Leigh (KPMG) examine the legal developments that strengthen HMRC’s ability to tackle cross-border non-compliance.
In most cases there will be little question as to whether the actions of both Parliament and the UK courts respect the basic principles of national sovereignty and the territorial limits of UK law. This is especially true in the world of tax yet recent years have seen an increasing boldness from both Parliament and the courts.
The latest development on extra-territoriality in the tax sphere has come from two unrelated sources:
a decision of the Court of Appeal in R (oao Jimenez) v The First-tier Tribunal [2019] EWCA Civ 51 (Jimenez); and
unrelated legislation from Parliament in the form of the Crime (Overseas Production Orders) Act (COPO) 2019 which received royal assent on 12 February 2019 but which has not yet been brought into force (the Act will instead come into force...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
