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Is it now inevitable corporates will face new “failure to prevent economic crime” offences?
Back in September 2014, the then Attorney General, Jeremy Wright QC MP announced that the Government was considering proposals to create a new corporate offence of failing to prevent economic crime. A change of corporate culture was sighted as being necessary to fully address the scale of fraud reported by the Global Economic Crime Survey.
Read moreTax update - April 2019
In this month’s update we report on (1) HMRC’s guidance on self-reporting failure to prevent the facilitation of tax evasion; (2) HMRC’s consultation on secondary preferential creditor status on insolvency of a business; and (3) a Parliamentary Select Committee’s call for a public register of beneficial ownership in each British Overseas Territory. We also comment on three recent cases relating to (1) the concept of “staleness” in discovery assessment appeals; (2) a failed DOTAS application brought by HMRC; and (3) the extra-territorial reach of HMRC information notices.
Read moreVAT update March 2019
In this month’s update we report on (1) HMRC’s updated guidance on claiming exemption from Making Tax Digital for VAT; (2) the latest edition of HMRC’s impact assessment for the movement of goods if the UK leaves the EU without a deal; and (3) HMRC’s policy change on VAT treatment of personal contract purchases.
Read moreNew corporate criminal offence: Failure to prevent the facilitation of tax evasion
The Criminal Finances Act 2017, which received Royal Assent on 27 April 2017, introduces new strict liability corporate criminal offences of failure to prevent criminal facilitation of tax evasion. The legislation came into force on 30 September 2017.
Read moreTax update - March 2019
In this month’s update we report on (1) clarification from HMRC on time limits for discovery assessments into tax returns where the loss of tax is due to avoidance; (2) HMRC’s updated guidance for settling disguised remuneration schemes; and (3) confirmation in Spotlight 48 that taxpayers who have taken out disguised remuneration loans do not need to obtain a deed of release or exclusion of the loan from the lender before HMRC will agree a settlement.
Read moreVAT Update - February 2019
In this month’s update we report on (1) changes to the VAT IT system rules and processes if the UK leaves the EU without a deal; (2) EU exit legislation; and (3) revisions to HMRC’s Notice of Making Tax Digital for VAT.
Read moreCustoms and excise quarterly update: February 2019
In this update we report on the effect of a no deal Brexit in relation to (1) customs processes and procedures; (2) binding tariff information; and (3) changes to tax procedures. We also comment on three recent cases relating to (1) obtaining an injunction when HMRC revoke Authorised Warehousekeeper status; (2) the application of retrospective inward processing authorisation periods; and (3) the seizure of vehicles.
Read moreCorporate tax update Fourth quarter 2018
Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s tax team and published quarterly. In this final 2018 edition we highlight some of the key tax developments of interest to UK corporates from the fourth quarter of 2018.
Read moreTax update - February 2019
In this month’s update we report on (1) an Economic Affairs Committee report on treating taxpayers fairly; (2) HMRC’s extension of the deadline for responses to its consultation on the taxation of trusts; and (3) the Law Society’s practice note on the offence of failure to prevent the criminal facilitation of tax evasion. We also comment on three recent decisions relating to (1) the principles governing disclosure in the context of tax appeals;(2) business property relief under the Inheritance Tax Act 1984; and (3) the closure of an HMRC enquiry which was “drifting aimlessly”.
Read moreVAT update - January 2019
In this month’s update we report on (1) refunds of VAT in the UK for non-EU businesses; (2) changes to the VAT treatment of retained payments; and (3) revised HMRC guidance on when and how to account for VAT when you transfer a business as a going concern. We also comment on three recent cases involving (1) irrecoverable output tax; (2) the deductibility of a repayment supplement from an interest award; and (3) whether a taxpayer had a legitimate expectation that HMRC guidance could be relied upon.
Read moreTax update December 2018
In this month’s update we report on (1) the published response to the consultation on creating a “fund structure” within the Enterprise Investment Scheme for investment in innovative knowledge-intensive companies; (2) the published response to the consultation on extending the IR35 rules to the private sector; and (3) the published response to HMRC’s tax abuse and insolvency discussion document. We also comment on three recent decisions relating to (1) penalties attaching to employment intermediaries returns (2); penalties for failing to file tax returns; and (3) CGT holdover relief where the transferor was a foreign controller of the transferee.
Read moreVAT update November 2018
In this month’s update we report on new regulations adopted by ECOFIN which are intended to combat VAT fraud, infringement proceedings brought against Italy and the UK following publication of the so-called “Paradise Papers” and publication of the response to HMRC’s consultation on the “split payment” method of VAT collection. We also comment on three recent decisions relating to the scope of the FTT’s jurisdiction in relation to public law issues, input tax recovery by a student union shop and application of the reverse charge rules to investment management services received from outside the EU.
Read moreCustoms and excise quarterly update November 2018
In this update we report on HMRC’s guidance on how to prepare for the Customs Declaration Service, the launch of the Customs Declaration Service and HMRC’s guidance on trading with the EU in the event of a no-deal Brexit. We also comment on three recent cases relating to the calculation of gaming duty, tariff classification of seasoned chicken meat and mobility scooters.
Read moreWealth and trusts quarterly digest
Welcome to our latest Wealth & Trusts digest. Our quarterly digest is specifically tailored for you and aims to provide up to date commentary, analysis and guidance on key sector developments. It is written by our wealth and trusts teams to assist you and your clients in responding to market trends and legal developments.
Read moreTax update November 2018
In this month’s update we report on proposals under consideration by the Treasury to extend capital gains tax relief to private landlords, HMRC’s factsheet on new higher penalties that it can impose where taxpayers have failed to declare and pay tax in relation to offshore matters and the annual report of Tax Inspectors Without Borders (TIWB). We also comment on three recent decisions relating to the partial writing-off of loans, Schedule 36 information notices and late filing penalties.
Read moreVAT Update October 2018
In this month’s update we report on changes to the VAT treatment of supplies of digital services, the European Parliament’s adoption of changes which are intended to simplify VAT for small businesses and the European Commission’s proposals for VAT rates and intra-EU supplies. We also comment on three recent decisions relating to the VAT option to tax a property third party access to documents filed at the First-tier Tribunal and the validity of Alternative Dispute Resolution agreements that are wrong in law.
Read moreCorporate tax update
Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s tax team and published quarterly. In this third 2018 edition we highlight some of the key tax developments of interest to UK corporates from the third quarter of 2018.
Read moreTax update October 2018
In this month’s update we report on HMRC’s Spotlight 45 on umbrella company avoidance schemes, an update to HMRC’s Venture Capital Schemes Manual; and call for evidence on HMRC powers.
Read moreVAT update September 2018
In this month’s update we report on the ECON committee’s amendments to the European Commission’s proposal for simplification of VAT for SMEs, the government’s technical note on the impact on VAT in the event of a no-deal Brexit; and Revenue and Customs Brief 6 (2018) on VAT exemption for all domestic service charges.
Read moreTax update September 2018
In this month’s update we report on HMRC’s updated position regarding payment of the April 2019 “loan charge”, HMRC’s updated guidance on the targeted anti-avoidance rule for close company distributions on a winding up and the CIOT’s comments on off-payroll working in the private sector. We also comment on recent decisions relating to, late filing penalties, an application by HMRC to amend its Statement of Case and tax geared penalties for failure to comply with information notices.
Read moreCorporate tax update
Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s tax team and published quarterly. In this second 2018 edition we highlight some of the key tax developments of interest to UK corporates from the second quarter of 2018.
Read moreVAT update August 2018
In this month’s update we report on HMRC’s revised guidance on the VAT cost share exemption, HMRC’s consultation and plans to address VAT avoidance via offshore looping, and making tax digital for VAT.
Read moreCustoms and excise quarterly update August 2018
In this update we report on changes to gaming duty accounting periods, HMRC’s policy paper on tobacco duty on heated tobacco and an amendment to the Export (Penalty) Regulations 2003. We also comment on three recent cases relating to the customs classification of Beyblades, excise duty assessment time limits and restoration of seized tobacco.
Read moreWealth and trusts quarterly digest
Welcome to our latest Wealth & Trusts digest. Our quarterly digest is specifically tailored for you and aims to provide up to date commentary, analysis and guidance on key sector developments. It is written by our wealth and trusts teams to assist you and your clients in responding to market trends and legal developments. We would welcome the opportunity to discuss any issues you may have and always welcome feedback on the content of our publications.
Read moreTax update August 2018
In this month’s update we report on the summary of responses to HMRC’s consultation on extending time limits for offshore non-compliance, HMRC’s policy paper on “profit-fragmentation” and HMRC’s consultation on proposals for new civil information gathering powers for HMRC.
Read moreVAT update July 2018
In this month’s update we report on the alignment of the period for recovery of VAT by exempt public sector entities; new guidance concerning VAT liability on goods supplied on approval; and HMRC’s policy paper on a new regime for interest and penalties.
Read moreNon-residents and UK property
Non-UK residents owning UK real estate, whether directly or via companies, partnerships, trust arrangements or collective investment vehicles, should be aware of important UK tax changes due to take effect from April 2019.
Read moreTax update July 2018
In this month’s update we report on new EU transparency rules for tax intermediaries, HMRC’s revised Disguised Remuneration Settlement Terms and the Law Society’s Response to HMRC’s consultation on Tax Avoidance involving profit fragmentation.
Read moreVAT update June 2018
In this month’s update we report on HMRC’s consultation on draft legislation imposing VAT reverse charge on the construction industry; the European Commission’s proposal concerning the taxation of intra-EU supplies; and HMRC’s recently published guidance on the VAT treatment of goods supplied on approval.
Read moreBrexit – trade and customs arrangements
In this Brexit Bulletin, we discuss trade and customs arrangements; what has been achieved in the last 6 months and the next steps moving forward.
Read moreTax update
In this month’s update we report on Guidance from HMRC on identifying who is an “enabler” of tax avoidance; a consultation on “off-payroll” working by contractors; and HMRC’s update to its International Exchange of Information Manual to reflect amendments to the list of reportable jurisdictions for Common Reporting Standards.
Read moreVAT update
In this month’s update we report on HMRC’s cooperation agreement, intended to tackle online VAT fraud; HMRC’s recently published Guidance on online marketplace seller checks; and the government’s pilot for Making Tax Digital for VAT.
Read moreWealth and trusts quarterly digest
Welcome to our latest Wealth and Trusts digest. Our quarterly digest is specifically tailored for you and aims to provide up to date commentary, analysis and guidance on key sector developments. It is written by our wealth and trusts teams to assist you and your clients in responding to market trends and legal developments. We would welcome the opportunity to discuss any issues you may have and always welcome feedback on the content of our publications.
Read moreTax update May 2018
In this month’s update we report on HMRC’s recently published guidance relating DOTAS for inheritance tax, its guidance for the GAAR and a new consultation relating to tax avoidance involving Profit Fragmentation.
Read moreCorporate tax update
Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s tax team and published quarterly.
Read moreVAT update April 2018
In this month’s update we report on the publication of the draft agreement on the UK’s withdrawal from the EU; the Government’s “split payment” collection model for online sales by non-UK sellers; and HMRC’s revised guidance on the cost sharing exemption.
Read moreTax update April 2018
In this month’s update we report on HMRC’s new Code of Practice 8 guidance, the OECD’s consultation on misuse of residence and citizenship schemes to circumvent the common reporting standard.
Read moreVAT update March 2018
In this month’s update we report on HMRC’s informal VAT grouping consultation; HMRC’s update on its project to digitise the VAT Retail Export Scheme and HMRC’s new guidance for Fast Parcel Operators.
Read moreTax update March 2018
In this month’s update we report on HMRC’s recently published guidance on the Serial Tax Avoidance Regime, venture capital schemes and non-domicile reforms.
Read moreWealth and trusts quarterly digest
Welcome to our latest wealth and trusts digest. Our quarterly digest provides up to date commentary and analysis on key sector developments. It is written by our wealth and trusts teams to assist you and your clients in responding to market trends and legal developments. We would welcome the opportunity to discuss any issues you may have and always welcome feedback on the content of our publications.
Read moreVAT update - February 2018
In this month’s update we report on the EU Commission’s proposals to reduce VAT compliance costs for small businesses, guidance published by HMRC following the Supreme Court’s decision in InvestmentTrust Companies and the latest consultation to implement “making tax digital” for VAT.
Read moreCorporate tax update
Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s tax team and published quarterly. In this final 2017 edition we highlight some of the key tax developments of interest to UK corporates from the fourth quarter of 2017.
Read moreTax update - February 2018
In this month’s update we report on HMRC’s recently published guidance relating to penalties for enablers of defeated abusive tax arrangements; the publication by the EU of a list of non-cooperative jurisdictions in tax matters; and the outcome of HMRC’s consultation on reporting obligations for offshore structures.
Read moreVAT Update - January 2018
In this month’s update we report on the VAT treatment of pension fund management services for insurers; the establishment of the EU cross-border prosecution service; and guidance published by HMRC following the Supreme Court’s decision in Littlewoods.
Read moreTax update December 2017
In this month’s update we report on HMRC’s increased activity in respect of the so-called Panama Papers; HMRC’s new guidance in relation to “enablers” of defeated tax avoidance schemes; new settlement terms concerning disguised remuneration; and HMRC’s updated Litigation and Settlement Strategy
Read moreVAT update November 2017
In this month’s update we report on the Office of Tax Simplification’s first report on VAT, the draft regulations concerning the fulfilment house due diligence scheme, and HMRC’s revised guidance on input tax deduction for funded occupational pension schemes.
Read moreCustoms and excise quarterly update, November 2017
In this update we report on the Government’s White Paper setting out its approach to the UK’s future customs, VAT and excise regimes; the Trade Bill 2017-2019; and the implementation of the Fulfillment House Due Diligence Scheme.
Read moreWealth and trusts quarterly digest November 2017
Welcome to our latest Wealth and trusts digest. Our quarterly digest provides up to date commentary and analysis on key sector developments. It is written by members of our wealth and trusts team to assist you and your clients in responding to market trends and legal developments. We would welcome the opportunity to discuss any issues you may have and always welcome feedback on the content of our publications.
Read moreTax update, November 2017
In this month’s update we report on HMRC’s revised guidance relating to venture capital schemes, the coming into force of section 166, Finance Act 2016 (offences relating to offshore income) and HMRC’s new guidance on self-reporting for failure to prevent the facilitation of tax avoidance.
Read moreCorporate tax update, third quarter 2017
Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s Tax Team and published quarterly.
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