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.
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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 are not a subscriber, subscribe now to read this content.
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