Bermuda Company Found UK Tax Resident

A company incorporated in Bermuda was UK tax resident because its strategic decisions were effectively made by a UK-based individual, the First-tier Tribunal has held in Cogefin (Bermuda) Limited and Giuseppe Ciardi v HMRC [2026] UKFTT 01108 (TC). The decision, dated 30 July 2026, highlights the importance of how an overseas company is actually managed. […]

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Italian Tax Residence: Supreme Court Confirms Decisive Role of Population Register

Order No. 24972 of 3 September 2026 also confirms that prior taxation of funds does not remove foreign asset reporting obligations. Italy’s Supreme Court has reaffirmed that, under the domestic rules applicable before 2024, registration in the Italian resident population register (Anagrafe della Popolazione Residente, or APR) for most of the tax year was sufficient […]

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No Formal Proposals Following HMRC Consultation on Simplifying the Taxation of Offshore Interest

HM Revenue & Customs (HMRC) has published a summary of responses to its consultation on simplifying the taxation of offshore interest. However, the UK government has confirmed that it will not put forward any formal proposals at this stage. The consultation examined the practical difficulties caused by the mismatch between the UK tax year and […]

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Draft Finance Bill 2027 legislation: tax treatment of stablecoins

On 13 July 2026, HMRC published a policy paper and draft legislation setting out a new tax treatment for eligible stablecoins. The proposals, which are intended for inclusion in the Finance Bill 2027, seek to align the taxation of stablecoins more closely with that of money and to simplify the rules for individuals, trustees and […]

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Court of Appeal confirms English domicile despite move to Italy

The Court of Appeal has dismissed a husband’s appeal in Ferrara v Ferrara, confirming that the wife retained her domicile of choice in England and Wales despite having moved to Italy with the family in 2019. The issue was significant because the wife had issued divorce proceedings in England and relied on her English domicile […]

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