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Tax and the City review for January 2021

Speed read
The EU/UK Trade and Co-operation Agreement gives the UK the freedom to narrow the scope of DAC 6 to just hallmark D (CRS avoidance and concealing beneficial owners). In Warshaw the UT dismisses HMRC’s appeal and concludes the FTT had made the right decision that the cumulative compounding preference shares held by the taxpayer were ‘ordinary share capital’ and that the company was his ‘personal company’ for the purposes of entrepreneurs’ relief. In Development Securities the Court of Appeal reinstates the FTT’s decision that the JerseyCos were tax resident in the UK. The latest report on the code of practice on taxation for banks shows the regime continues to work but that HMRC needs to improve its response time for pre-transaction approaches. The UT in Gallaher decides to make a reference to the CJEU in order to resolve the appeal on whether the UK’s exit tax regime...
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