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One thing that can be clearly seen amid all the arguments over the status of Lord Ashcroft is that neither the press nor the politicians really understand the difference between someone being resident in the UK or being domiciled in the UK. But we shouldn’t really blame them as the subject has long been one […]

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To try and deal with some of the economic problems encountered last year when Ireland’s “Celtic Tiger” economy collapsed in chaos, the Irish Government introduced a tax holiday for companies which commenced trading during 2009 under which, subject to certain conditions, they would pay no tax for a three year period. As things have not […]

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“Transfer pricing” is an increasingly important and contentious area of international tax law. This is because so much of modern world trade involves the transfer of goods, intangibles or services within multinational enterprises (MNEs) – groups of companies or related businesses based in 2 or more countries. Such international trade offers scope for an MNE […]

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The Liberal Democrat Shadow Chancellor has been a stern critic of the Isle of Man, calling us a haven for tax dodgers. He also demanded that the Isle of Man be closed as a ‘tax haven’ and for banks receiving investment from the UK Government to shut offshore operations. Despite that he accepted an invitation […]

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There are stunned expressions on the faces of Isle of Man politicians, civil servants and business leaders who have just read an official press statement from Stephen Timms, Financial Secretary to the UK Treasury, seen here behind his political master Gordon Brown. After months, indeed years of undisguised hostility, most blatantly with Chancellor Alistair Darling’s […]

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I live in the Isle of Man. For those of you who don’t know this is a small island in the middle of the Irish Sea about midway between England, Scotland and Ireland (and a little further from Wales).   Although one of the British Isles we are an independent country – with the oldest […]

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I recently received a question from the owner of a UK company questioning the imposition of Spanish withholding tax on payments his company received from a Spanish subsidiary. He thought that the EU Parent-Subsidiary Directive exempted the tax. In fact it would do for dividends but not for royalty payments, which these payments were for […]

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The British Treasury has set up an independent review to examine the operations of offshore financial centres and their effect on the UK economy. The review will look at the current and future risks posed by the current economic crisis to the financial business of British Crown Dependencies and Overseas Territories including Jersey, Guernsey, the […]

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There has been much publicity and comment about “non doms” – these being persons who whilst resident in the UK are not domiciled there (see here for more information on what this means). The popular belief is that these people are unfairly avoiding tax on income or capital gains made outside the UK by claiming […]

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HMRC (Her Majesty’s Revenue & Customs) have announced that they are gearing up to mount an attack on Managed Service Companies (MSCs) based in the UK and offshore. Background For many years now HMRC has battled to try and stop what it perceives to be the unacceptable use of limited companies as a way for […]

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Ken Henry, Australia’s Treasury Secretary today unveiled the first in a series of long awaited consultation papers which are aimed at simplifying the country’s overcomplicated tax system in a bid to attract greater investment into the country. Currently Australians are subject to 125 different taxes, but the vast majority of government revenue (about 90%) is […]

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International businessman Robert Gaines-Cooper has failed to persuade the Court of Appeal that he has changed his UK domicile. We read a lot in the UK press about “non-doms” and how they don’t pay their fair share of tax. Recent legislation has made it more difficult for “non doms” to benefit but as usual the […]

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