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 […]
In Revenue and Customs Commissioners v Professional Game Match Officials Ltd (2024), the Supreme Court was called to determine the employment status of football referees engaged by Professional Game Match Officials Ltd (PGMOL). The key issue was whether these referees should be considered employees for tax purposes, which would obligate PGMOL to deduct income tax […]
A new policy paper was recently published by HMRC with more details around the new non-dom tax rules effective from 6 April 2025. Below is an overview of the key points: End of Remittance Basis The government confirmed that the 2024/25 tax year will be the last year for which the remittance basis can be […]
The Italian government has announced a significant increase in the tax charge for individuals who transfer their tax residency to Italy, doubling the amount to €200,000. Under Italian law, similar to the UK, residents are taxed on their worldwide income. However, there is a special provision for those relocating to Italy, provided they have been […]
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 […]
