Market leading insight for tax experts
View online issue

Private client review for February 2021

Speed read
The OECD has published new guidance on the interpretation of double tax treaties in the context of lockdown restrictions, followed by updated HMRC guidance on ‘exceptional’ days. Bitcoin owners looking to realise gains following the recent surge in values are reminded that the location of bitcoins for tax purposes matches the residence of the owner. In Fastklean, the FTT confirmed that open justice principles may be relied upon to grant a barrister access to previously unseen HMRC internal guidance. In Kennedy, HMRC successfully challenged a claim for entrepreneurs’ relief on the basis that the taxpayer was not an officer or employee of the company or the trading group in question in the period leading up to the disposal.

If you or your firm subscribes to, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.