Mark Davies’ observations on Spain’s IHT reversal for non-EEA residents

Spanish court throws out Spain’s higher IHT for non-EEA residents In a landmark case, the Spanish court has ruled that a long-standing and controversial practice of charging non EEA-residents of Spain inheritance tax is discriminatory and therefore, unlawful. Potentially, this sets the stage for those who have paid inheritance tax in the past to file…

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HMRC Requirement to Correct – how to avoid punitive penalties

The UK has introduced new penalties under the Requirement To Correct (“RTC”). The RTC imposes an obligation on anyone who has under-declared UK tax liabilities to make a disclosure to HM Revenue & Customs (“HMRC”), the UK tax authority. Failure to disclose by 30 September 2018 will result in punitive penalties. The standard penalty is between 100%…

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Cleansing and rebasing opportunities for non-doms – time to act

A window of opportunity for cleansing and rebasing Those heading for deemed domiciled status have opportunities to protect their assets now through protected trusts, cleansing and rebasing assets. What is a ‘nondom’? A nondom is someone with a foreign (non-UK) domicile. Domicile is a curious concept in English law. It is not the same as tax…

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