This month, we comment on the ramifications of the recent decision in Embiricos, where the Court of Appeal confirmed that HMRC has no power to issue a partial closure notice in respect of a remittance basis claim without specifying the increased tax due. Economic substance rules in offshore jurisdictions are widening again, with the European Commission targeting a similar regime in the EU. Two recent SDLT cases looking at multiple dwellings relief, together with a government consultation, suggest that this area is ripe for reform, while a PPR case serves as a reminder that the ‘quality’ of a taxpayer’s occupation of a property is a key component in applying the relief. Finally, guidance is developing in relation to the upgraded trust registration service.
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This month, we comment on the ramifications of the recent decision in Embiricos, where the Court of Appeal confirmed that HMRC has no power to issue a partial closure notice in respect of a remittance basis claim without specifying the increased tax due. Economic substance rules in offshore jurisdictions are widening again, with the European Commission targeting a similar regime in the EU. Two recent SDLT cases looking at multiple dwellings relief, together with a government consultation, suggest that this area is ripe for reform, while a PPR case serves as a reminder that the ‘quality’ of a taxpayer’s occupation of a property is a key component in applying the relief. Finally, guidance is developing in relation to the upgraded trust registration service.
If you are not a subscriber, subscribe now to read this content.
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