Transfer of assets abroad: mind your motives
The transfer of assets abroad (ToAA) code is a cornerstone of the UK’s anti-avoidance regime, designed to prevent individuals from avoiding UK income tax by transferring assets to persons abroa
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Inheritance tax and foreign doms: a welcome simplification?
The 2024 Budget announced several major changes for inheritance tax, marking a radical reform of this tax akin to the 2006 changes for trusts.
Merged R&D scheme: impact on quarterly instalment payments
The merged research and development (R&D) tax relief scheme was introduced for accounting periods beginning on or after 1 April 2024.
Motorbikes, yachts and horses: private or mixed use?
Yachts and horses have often been grouped together as targets for HMRC with regards to private usage.
Closing the tax gap: government strategy on non-compliance
On 26 March 2025, the Chancellor of the Exchequer Rachel Reeves delivered the Spring Statement 2025, unveiling a comprehensive package of measures designed to add
The case of Quillan v HMRC: the dangers of a director’s loan account
I can remember the first time I saw a corporation tax assessment seeking tax on a loan to a participator.
The drama of US tariffs: a practical response
In April, US President Donald Trump introduced a swathe of increased tariffs (or customs duties) in an attempt to stamp out trade deficits and encourage corporati
Facing a HMRC investigation: a practical response
An HMRC investigation or enquiry can be a worrying development for a business but for those in HMRC’s ‘Large Business Service’, it is par for the course.
The evolving BEPS landscape: the impact on multinationals
As the international tax landscape continues to evolve, the base erosion and profit shifting (BEPS) initiative remains at the forefront of global tax policy.