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In a report published yesterday, the Organisation for Economic Cooperation & Development (OECD) calls for an overhaul of international tax laws, including controversial transfer pricing rules, in an effort to stamp out corporate tax avoidance. The report addressed concerns from many quarters that global companies have opportunities to “profit shift” from high to low tax […]

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At its simplest, tax planning is just a case of arranging your financial affairs in such a way as to pay as little tax as possible within the law and so not much different from “tax avoidance”. Politicians and the media are struggling to agree exactly what “tax avoidance” is and are starting to use […]

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The courts of most countries have long accepted that taxpayers have the right to arrange their financial affairs in such as manner as to use tax legislation to reduce the amount of tax that is payable by means that are within the law. For centuries the mantra “evasion is illegal but avoidance is not” has been […]

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Following on from the success of the recent Liechtenstein Disclosure Facility, which has already resulted in HM Revenue & Customs recovering £363 million in unpaid tax and which is expected to bring in at least ten times that sum over the next five years, the two countries signed a full double taxation agreement (“DTA”) yesterday. […]

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It comes as no surprise that the UK Government has accepted the recommendation of Graham Aaronson QC that a General Anti-abuse Rule (GAAR) should be introduced into the UK tax system to tackle what it sees as misinterpretation of legislation. The aim of the GAAR is to allow tax avoidance to be tackled without making […]

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One of the reasons that you won’t often find me commenting on US tax issues is that the US government have a lot of very nasty laws that they are prepared to use on anyone they think might be encouraging their citizens to evade or even just avoid tax – even though tax avoidance is […]

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On July 20th this year the Chancellor George Osborne announced the establishment of the Office of Tax Simplification (“OTS”) charged with the task of providing the Government with independent advice on simplifying the UK tax system. Not before time! Today the OTS announced details of two initial reviews, which are to be completed before the […]

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Is offshore banking legal? This is a question often asked these days, as various nations seek to clamp down on offshore tax havens and offshore banking. And while such banking may raise eyebrows in certain quarters, or invite disapproving comments from politicians seeking to balance budgets and maximise tax revenue, the fact is banking offshore […]

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Capital Gains Tax (“CGT”) was introduced by Harold Wilson’s Labour Government in 1965. Its purpose was simple: To tax the profit or “gain” made on the sale or “disposal” of an asset by individuals. Companies do not pay CGT but instead any gain is taxable as part of their Corporation Tax bill. The original reason […]

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The Enterprise Investment Scheme offers generous income tax and capital gains tax reliefs to investors in certain companies. These reliefs are available to “qualifying individuals” who subscribe for “eligible shares” in “qualifying companies” undertaking “a qualifying business activity”. Simple, isn’t it? The purpose behind the scheme is to encourage investment in start up companies and […]

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Now that George Osborne has finally made it to 11 Downing Street and is planning his “Emergency Budget”, I hope he look seriously at reducing the headline rate of Corporation Tax in order to attract international businesses to the UK as well as stemming the flow of UK companies moving their tax residence elsewhere. The […]

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I was talking to an Independent Financial Advisor a couple of days ago and in conversation asked him how he was getting on winding up the estate of a mutual client who died about 18 months ago. “Fine”, he said, “but it looks like we have paid too much Inheritance Tax on the house” – […]

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Just over a year ago I wrote about the visit to the Isle of Man undertaken by Vince Cable, then Liberal Democrat Shadow Chancellor who today was appointed Secretary of State for Business and Banking in the new Conservative – Liberal cabinet. Despite having been a stern critic of the island, calling it a tax […]

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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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Benjamin Franklin said, “In this life nothing is certain but death and taxes”. When anyone who is resident or domiciled in the UK dies those they leave behind will find that HMRC will want a slice of the dead person’s estate – their money, house, possession etc. This tax used to be called Death Duties […]

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Any business can claim tax allowances, called capital allowances, on certain purchases or investments. This results in a reduction in the business tax bill – which can’t be bad. In general capital allowances are available on plant and machinery, buildings – including converting space above commercial premises to flats for renting – and research and […]

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I’ve suddenly had a lot of people contact me to ask the above question regarding the tax free ISA (Individual Savings Account) products that are available to UK taxpayers. This is probably due to changes that came in last month. If you don’t know what an ISA is then have a look at this earlier article. […]

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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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On his 2008 Presidential campaign trail, Barack Obama made his hostility toward “offshore” jurisdictions very clear: “There’s a building in the Cayman Islands that houses supposedly 12,000 U.S.-based corporations. That’s either the biggest building in the world or the biggest tax scam in the world, and we know which one it is.” I know that […]

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HM Revenue & Customs are facing a flood of legal claims that will blow another massive hole in the public finances. In the past few weeks thousands of High Court claims have been lodges by companies and local councils relating to millions of pounds of interest wrongly charged by HMRC. When HMRC makes a repayment […]

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