Mark Davies in the Telegraph on Offshore Income and Gains letters

In Monday’s Telegraph Laura Miller explores the repercussions of returning a signed offshore income and gains letter to HMRC. https://www.telegraph.co.uk/tax/return/dont-sign-dotted-line-warning-hmrc-letters-could-trigger-tax/ In this article Mark Davies explains that signing the disclosure might prevent a taxpayer from being able to claim an unprompted disclosure of a mistake, which would lead to higher penalties. He also warns that…

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HMRC Certificate of Tax Position? What should you do?

HMRC have started to contact UK taxpayers about their offshore income and gains, showing that the UK’s participation in the Common Reporting Standard (“CRS”) is in full force.  What is the Common Reporting Standard? Over 100 countries have signed up to CRS and information regarding the level of income and gains earned by worldwide taxpayers…

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A plea for a Who’s Who? of Highly Compliant Lawyers

In the aftermath of the Panama/Paradise Papers, the International Bar Association (IBA) and the Secretariat of the Organisation for Economic Co-operation and Development (OECD) have issued eight principles for the legal profession to follow. Few people would disagree with Principle 1 that ‘you should not unwittingly help a client hide illegal conduct’, or Principle 3…

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Mark Davies reveals a warning for non-doms in ePrivateClient the leading online news service for private client practitioners.

There is a stark warning for non-doms with offshore structures in HMRC’s recent publication “No Safe Havens 2019”. Last year HMRC received 5.67 million records of UK tax payers’ offshore bank accounts under the Common Reporting Standard. They correlated these with the tax return submissions and property sale information of 500,000 individuals. Illegal tax evasion…

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Why Dutch Sandwiches are off the menu in Overseas Territories and Crown Dependencies

Contrary to popular belief, international tax planning is not so much about avoiding tax. Usually advisers help their clients avoid being taxed more than once on the same profits. Use of Dutch Sandwiches or Subsidiary Companies It is not uncommon for a subsidiary company to pay local tax on its trading revenues, then declare a…

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Protected Trusts – what action should our clients take?

HAVE PROTECTED TRUSTS TURNED INTO FALSE PROMISES? Those worrying about what else has been neglected, whilst the UK government’s attention is wholly fixed on Brexit and infighting, will take no comfort from HM Revenue’s recent statement that offshore income gains are not within the new Protected Trusts regime. Background The introduction of the Deemed Domicile rules for income and capital gains tax from April 2017 ended the unlimited access…

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