Background: in D’Angelin v Revenue and Customs Commissioners [2024] UKFTT 00462 (TC) Mr. Benoît D’Angelin, a UK resident but non-domiciled financier, invested £1.5 million of his foreign income into a newly founded UK company, D’Angelin and Co Ltd, anticipating that the investment would qualify for Business Investment Relief (BIR), rendering it non-taxable. The company provided […]
In the matter of Osmond and another v HMRC [2024] UKFTT 378 (TC), the First-tier Tribunal (FTT) adjudicated that taxpayers who executed a share buyback with the objective of crystallizing Enterprise Investment Scheme (EIS) relief from capital gains were deemed, as a matter of law, to have a main purpose of obtaining an income tax […]
On the 6th of March 2024, the Chancellor Jeremy Hunt announced the Spring Budget for the financial year 2023/2024. Although the priorities are still to reduce inflation below the 2% target, grow the economy and get debt falling, the Government confirmed that inflation has fallen from last year, growth has been more resilient than expected, […]
The Scottish government recently implemented changes in income tax rates for higher earners, increasing the disparity between taxes paid by affluent individuals in Scotland versus their counterparts across the UK. Shona Robison, the finance secretary unveiled a new income tax band of 45 percent applicable to individuals earning between £75,000 and £125,140 annually. Moreover, for […]
On 5 December 2023, HMRC confirmed that the double tax treaty (DTT) signed by the UK and San Marino on 17 May 2023 entered into force on 30 November 2023. This DTT will have effect in San Marino from 1 January 2024 and in the UK:
