Estate Planning using Double Tax Agreements – Should you be doing more?  

HMRC have successfully challenged a taxpayer’s domicile of choice on death, such that the taxpayer was unable to benefit from the highly beneficial India-UK Double Tax Agreement (“DTA”). This article discusses how the First Tier Tribunal reached their conclusion and highlights the need to ensure that “intentions” can be substantiated on demand.   Inheritance Tax (“IHT”)   …

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Is it time to review your Domicile Status after recent HMRC challenge?

Recent cases in the courts underpin how fundamental it is to ensure that intentions regarding domicile, i.e., where a person’s permanent home is, are backed up by facts and actions. Historically, HM Revenue & Customs (“HMRC”) have been known to dispute an individual’s domicile status post-death, and for good reason. Once the taxpayer in question…

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HMRC opens Pandora’s Box – What should I do if I am contacted about being named in Pandora Papers?

The Pandora Papers were the biggest release of offshore data to date, involving the leak of millions of documents in October 2021 by a number of offshore financial service companies. Letters have been issued to some individuals named in the Pandora Papers Having taken time to review the leaked information, HMRC have now begun the…

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Inflation is the Enemy – The Chancellor’s Autumn Statement

With inflation rising and following the financial markets’ reaction to the not-so mini, mini-budget, Chancellor Jeremy Hunt’s Autumn Statement had to build global confidence in the UK economy once more. Put crudely, the tax-take had to increase and expenditure needed to decrease. At least the incumbent Chancellor couldn’t do any worse than his predecessor… After…

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Kwasi Kwarteng’s Mini-Budget

Today Kwasi Kwarteng, the newly appointed Chancellor of the Exchequer, announced his first, albeit “Mini”, Budget.  The speech confirmed some well publicised changes, but also included a number of eye-catching announcements aimed at stimulating investment and driving growth in a bid to tackle rising energy prices and the increased cost of living.  We highlight below…

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UK’s Register of Overseas Entities (“ROE”)

What is ROE?   The ROE is the UK’s application of the requirement to register the beneficial owners of overseas companies that own UK land and property.  It requires all companies owning UK land and property to provide details of their beneficial owners to Companies House; if suitable details aren’t provided, the entities will be prohibited…

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