The Court of Appeal has reaffirmed HMRC’s longstanding approach to the place of effective management (POEM) of trusts in the context of pre-2006 “round-the-world” tax avoidance schemes. In Haworth v HMRC [2025] EWCA Civ 845, the Court held that the POEM of a trust that had briefly appointed Mauritian trustees was, in substance, in the […]
In a decision with important implications for property investors and developers, the Court of Appeal has upheld HMRC’s interpretation of “residential property” for Stamp Duty Land Tax (SDLT) purposes, confirming that substantial renovation needs do not necessarily disqualify a property from being treated as residential. In Mudan v HMRC [2025] EWCA Civ 799, the taxpayers […]
In a significant decision for non-domiciled individuals claiming Business Investment Relief (BIR), the Upper Tribunal has confirmed that any extraction of value from a company in which a qualifying investment has been made may trigger a clawback of relief, even if there is no net benefit to the investor. In D’Angelin v Revenue and Customs […]
The UK government has introduced new reporting obligations for crypto asset service providers, aligning with the OECD’s Crypto-Asset Reporting Framework (CARF). The Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations 2025 (SI 2025/744), enacted on 24 June 2025, will come into force on 1 January 2026. Under the new rules, UK-based Reporting Crypto […]
On 23 April 2025, HMRC published Spotlight 69, drawing attention to arrangements involving the liquidation of Limited Liability Partnerships (LLPs) aimed at avoiding Capital Gains Tax (CGT) liabilities. How the Schemes Operate Typically, the arrangements involve the following sequence: Promoters claim that these steps allow the properties to be transferred into a corporate structure without […]
