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IN BRIEF

Views on recent developments in tax.

The fallout from failed tax saving arrangements using employee benefit trusts (EBTs) continues. In Hunt v Richard Balfour-Lynn (and others) [2022] EWHC 784 (Ch), directors who in reliance on tax advice from a firm of accountants, arranged for a company to use an EBT, were found not in breach of duty. The decision whilst of comfort to directors, increases the likelihood of recovery actions following failed tax saving schemes shifting back on the accountancy firm tax advisers.

There are some helpful relaxations of the rules on marriage or civil partnership breakdown.

What the draft UK implementing legislation tells us.

Significant changes to HMRC’s data collection and sharing powers are proposed.

Perhaps inevitably, there are some modifications to the new regime.

In the summary of responses to its consultation on Helping taxpayers get offshore tax right, the government has proposed innovative ways to assist taxpayers to identify and declare their non-UK income and assets.

Lessons from a recent Upper Tribunal judgment, including for HMRC.
The EC’s ‘SAFE’ proposal raises more questions than answers.
The fact that trade-related properties ‘are valued by reference to trading potential does not mean that two separate assets are being valued’, the Court of Appeal finds.
The case of BlueCrest Capital Management (UK) LLP v HMRC [2022] UKFTT 204 (TC) has implications for many LLPs within the professional services and investment management sectors. 
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