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Offshore
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OFFSHORE
Other cases that caught our eye: 30 August 2024
Offshore employment: Bilfinger Salamis UK Ltd v HMRC [2024] UKFTT 736 (TC) (16 August) concerns the so-called host employer rules which apply where the ‘personal services’ of individuals employed by a foreign employer are ‘made...
Ask an expert: Offshore trusts and trustee borrowing
Julie Howard
Julie Howard (Boodle Hatfield) considers the ways of funding distributions to beneficiaries from an offshore trust, some of whom are UK resident.
Privileged documents and third party notices: how far do HMRC’s information powers reach?
Oliver Marre
Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.
VAT grouping disputes: the implications of HSBC
Sarah Bond
Sarah Bond (Freshfields Bruckhaus Deringer) examines the Upper Tribunal decision that represents what is likely to be the first major instalment in a series of cases on the VAT grouping of offshore service companies.
International business operating models: the tax issues
Gavin Orpwood
Louise Keegan
Hannah McKenzie
Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the
tax risks to international business operating models.
Tax transparent property funds
Alexandra Hawkins
Toby Price
Toby Price and Alexandra Hawkins (Deloitte) discuss the SDLT treatment of
tax transparent funds investing in UK real estate.
Jersey’s economic substance rules
Rupert Lee
Rupert Lee (Deloitte) examines Jersey’s newly introduced economic substance legislation.
The FTT’s recent approach to transfers of assets abroad
Rory Mullan
Rory Mullan (
Old Square Tax Chambers) examines two
cases that demonstrate the importance of establishing the
fundamental requirements of the TOAA code before a
charge can be imposed.
Private client review for July 2019
Andrew Goldstone
Jonathan S. Betesh
Andrew Goldstone and Jonathan S. Betesh (Mishcon de Reya) review the
latest tax developments affecting private clients.
Tax and the City review for June 2019
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
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EDITOR'S PICK
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
1 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
2 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
3 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
4 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
5 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
6 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
7 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
NEWS
Read all
Tax Journal authors for February 2025
Special report: The consultation on the impact on trusts of forthcoming reforms to BPR and APR
HMRC manual changes: 7 March 2025
HMRC consult on APR/BPR changes for trusts
Finance Bill passes Report Stage
CASES
Read all
HMRC v Appellants in the Post Prudential Closure Notice Group Litigation
C Poulton v HMRC
Advanced Hair Technology Ltd v HMRC
Other cases that caught our eye: 7 March 2025
The executors of L Elborne deceased and others v HMRC
IN BRIEF
Read all
The Good, the Bad and the Ugly: the IHT consultation on agricultural and business property
Home loan schemes: lessons from Elborne
New HMRC guidance on subcontracted and subsidised R&D
Finance Bill Report Stage amendments to the non-dom reforms
Statutory residence: but why do you need to be here?
MOST READ
Read all
HMRC advisory fuel rates
Government proposes further Finance Bill amendments, including to the temporary repatriation facility
Finance Bill Report Stage amendments to the non-dom reforms
Advanced Hair Technology Ltd v HMRC
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle