The Court of Appeal recently handed down its judgment in the Hoey case. The case is noteworthy because it helps illustrate the extent of HMRC’s powers to collect tax by shifting compliance obligations from one person to another. As can be readily appreciated, this could be particularly of note for directors of companies that have … Continue Reading
Following the UK business secretary offering assurance that HMRC will take a ‘cautious approach’ to recovering tax debts (see our previous blog), HMRC has now published guidance outlining its approach. This guidance also explains how HMRC might respond where a business has taken advantage of one of the government backed lending schemes (such as a … Continue Reading
We highlighted in our previous blog, the pivotal role that HMRC could play in ensuring the survival of UK businesses when all COVID restrictions are lifted and the government’s various temporary support measures come to an end. The Business Secretary, Kwasi Kwarteng, has now assured business that HMRC will take a “cautious approach” to recovering … Continue Reading
HMRC expect all UK taxpayers to pay the tax they owe, in full and on time, whenever they are able to do so. However, in circumstances where a taxpayer is unable to meet its liability, HMRC are able to exercise a discretion to allow the taxpayer to pay tax after the due date, over an … Continue Reading
The UK Spring Budget Statement delivered by Chancellor of the Exchequer, Rishi Sunak, on Wednesday 3 March 2021, laid bare the scale of the economic damage done by COVID-19. The Chancellor’s focus was on initiating an investment-led recovery, to incentivise investment, productivity and growth and to build a new, innovative and “green”, UK economy. In … Continue Reading
While much of the focus of the insolvency and restructuring world has (rightly and understandably) been on the fundamental changes introduced under the Corporate Insolvency and Governance Act 2020, it is worth remembering that there have been major tax changes too. The Finance Act 2020 introduced new rules making directors, shadow directors and certain others … Continue Reading
Some of the businesses most severely affected by the Covid-19 pandemic operate in the retail, hospitality and leisure sector, with many being instructed by the Government to close down. For many of those same enterprises, business rates probably represent a (if not the) major operating cost. In attempt to alleviate some of the financial damage, … Continue Reading
This note provides a more detailed look at what tax measures and announcements have been made to date covering: VAT, self assessment income tax, time to pay, non-statutory clearances, pension schemes, statutory residence test, stamp duty (transfer of shares and applications for group relief). It also highlights other measures that we could see to address the … Continue Reading
The UK Government has announced that, in order to assist businesses dealing with the effects of the COVID-19 pandemic, no UK business would be required to pay VAT due between 30 March 2020 and 30 June 2020. Instead, the sums that would have fallen to be paid this quarter will not become due until the … Continue Reading
The question whether restructuring profits are taxable or not has been answered differently in Germany in the past. However, on 7 February 2017, a decision of the Grand Senate of the Federal Fiscal Court (the “FFC Decision”) was published, in which the highest German tax court declared the Restructuring Decree as unlawful. The FFC found that … Continue Reading
Due to the introduction of new tax legislation on 6th April 2016, distributions made to shareholders of companies undergoing Members’ Voluntary Liquidation (MVL) are now treated as income (rather than capital) and are taxed accordingly. The result is that the tax rate on MVL proceeds has shot up to a staggering 28%, as detailed in our previous article. For distributions to … Continue Reading
Businesses should be aware that new anti-avoidance tax rules will take effect from 6 April 2016 which will have a negative impact on members’ voluntary liquidations (“MVLs”). The new rules are part of a crackdown by Revenue and Customs to avoid ‘income-into- capital’ tax planning. This is probably in part due to the higher dividend … Continue Reading
The vast majority of UK taxpayers pay what they owe in full and on time. Her Majesty’s Revenues and Customs (HMRC) thinks that a persistent minority choose not to pay which provides an undeserved advantage to those who are wilfully seeking to play the system, and creates costs which are ultimately borne by the compliant … Continue Reading
