OFFSHORE

Offshore employment: Bilfinger Salamis UK Ltd v HMRC [2024] UKFTT 736 (TC) (16 August) concerns the so-called host employer rules which apply where the ‘personal services’ of individuals employed by a foreign employer are ‘made...

Julie Howard

Julie Howard (Boodle Hatfield) considers the ways of funding distributions to beneficiaries from an offshore trust, some of whom are UK resident.

Oliver Marre

Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.

Sarah Bond

Sarah Bond (Freshfields Bruckhaus Deringer) examines the Upper Tribunal decision that represents what is likely to be the first major instalment in a series of cases on the VAT grouping of offshore service companies.

Hannah McKenzie Gavin Orpwood Louise Keegan

Hannah McKenzie, Louise Keegan and Gavin Orpwood (PwC) examine the tax risks to international business operating models.

Toby Price

Alexandra Hawkins

Toby Price and Alexandra Hawkins (Deloitte) discuss the SDLT treatment of tax transparent funds investing in UK real estate.

Rupert Lee

Rupert Lee (Deloitte) examines Jersey’s newly introduced economic substance legislation.

Rory Mullan

Rory Mullan (Old Square Tax Chambers) examines two cases that demonstrate the importance of establishing the fundamental requirements of the TOAA code before a charge can be imposed.