OFFSHORE

Kevin Offer (Hardwick and Morris) examines the tribunal decision in Hull City AFC (Tigers) Ltd v HMRC that provides the first judicial guidance since the Sports Club case on how to approach the question of whether a payment for image rights constitutes earnings.

Four recent commentaries examine different aspects of the tax compliance landscape.

Kelly Sizer

From 2019, HMRC will have 12 years to raise assessments on offshore matters, even if the taxpayer has made an innocent error. This will catch years back to 2013/14 where the taxpayer has been careless, or 2015/16 where the taxpayer made a mistake despite taking reasonable care.

Andrew Goldstone

Natalie Quail

Andrew Goldstone and Natalie Quail (Mishcon de Reya) consider the eagerly anticipated measures that have been published.

Nigel Barker Jenny Tevlin Annis Lampard

Nigel Barker, Annis Lampard and Jenny Tevlin (Deloitte) examine what Schedule 36 powers mean in practice, and unwrap the latest trends in HMRC analytics.

Simon Whitehead

Sarah Tulip

Simon Whitehead and Sarah Tulip (Joseph Hage Aaronson) consider the implications, and legality, of the new 25% tax on transfers to pensions outside the UK.

Andrew Goldstone

Victoria Howarth

In this month’s briefing, Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments in the private client arena, including the new non-dom proposals; changes to the IHT residence nil-rate band provisions; the end of offshore disclosure facilities; and views and behaviours in relation to ATED.