On 14 October 2024, the Independent Expert Panel, which was convened in December 2023 to guide the government on establishing a corporate re-domiciliation framework in the UK, published its much-anticipated report. This follows the UK government's initial consultation on introducing a corporate re-domiciliation regime in October 2021. Key Recommendations from the Report: The UK government […]
In a recent Upper Tribunal case, Amarjeet Mudan and Tajinder Mudan vs HMRC [2024] UKUT 00307 (TCC), the critical issue of whether a building is "suitable for use as a dwelling" was at the heart of the dispute regarding Stamp Duty Land Tax (SDLT). The case revolved around the Mudans' purchase of a property in […]
In the case Putney Power Ltd v Revenue and Customs Commissioners, the core issue revolved around whether the company had commenced a "qualifying trade" for the purposes of the Enterprise Investment Scheme (EIS) under section 189 of the Income Tax Act 2007. The concept of "trade" in this context is critical because EIS relief is […]
In the recent case of Kevin McCabe v HMRC ([2024] UKUT 00280 (TCC)), the Upper Tribunal examined whether Mr. McCabe had ceased to be a UK resident during the tax years 2006/7 and 2007/8. The case involved complex issues of tax residency under both common law and the UK/Belgium Double Tax Convention (DTC), ultimately concluding […]
HMRC has recently launched a new wave of "nudge" letters aimed at individuals listed as Persons with Significant Control (PSCs) of companies. These letters are part of an effort to ensure that PSCs are meeting their tax obligations, with a particular focus on two groups: The clear implication from HMRC’s briefing suggests that their view […]
