TAX-PLANNING

Gerald Montagu Evelyne Bagdassarian José Ramón Vizcaíno

A letter from Paris and Madrid, coupled with some reflections on the proposed direct tax Omnibus Directive/Recast DAC 6 Directive and recent Court of Appeal judgments, by Evelyne Bagdassarian, José Ramón Vizcaíno and Gerald Montagu (Stephenson Harwood).

Cristy Ajediti

Helen Coward

Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.

UT confirms broad meaning of ‘business’

Share loss relief: S Wilders v HMRC [2026] UKFTT 517 (TC) (1 April) is a claim for share loss relief arising from a failed attempt to recover treasure from the wreck of the ship the Merchant Royal, which sunk in 1641 off Land’s End. Investors...

IHT implications under Forfeiture Act: Under the Forfeiture Act 1982, a person who has unlawfully killed another person cannot benefit from that person’s estate. However, where in the opinion of the court the justice of the case requires...

David Alcock

Ritchie Tout

David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain why these structures are increasingly under the spotlight.

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...

Michael Thomas KC

The position should be calmly evaluated at an early stage in order to put an appropriate strategy in place, writes Michael Thomas KC (Pump Court Tax Chambers). Easy to say in theory, but not always so easy to execute in practice...