TRANSFER-OF-ASSETS-ABROAD

The Finance Bill measures have created more questions than answers, writes Emily Osborne (Stephenson Harwood).

Edward Reed

PPR relief, transfer of assets abroad, information notices and the taxation of finder’s fees are among the topics in this month’s review by Edward Reed and Angus Richardson (Macfarlanes).

Each week, Tax Journal reports notable judgments on tax issues that have been handed down by the courts and tribunals. This week, we also look back over 2023 and highlight some cases of interest to a wide range of advisers.

Ben Elliott

The Supreme Court has effectively left it open to future courts to counteract artificial avoidance, writes Ben Elliott (Pump Court Tax Chambers).

Hugh Gunson

Guy Bud

Hugh Gunson and Guy Bud (Charles Russell Speechlys) examine the Court of Appeal’s decision which has potentially far-reaching consequences for the PAYE system.

Josie Hills

Abigail McGregor

Josie Hills and Abigail McGregor (Pinsent Masons) examine one of the oldest statutory tax avoidance regimes that continues to apply.

Oliver Marre

Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.

Adam Craggs

Constantine Christofi

Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).

Edward Reed

Georgia Rawlinson

Edward Reed and Georgia Rawlinson (Macfarlanes) provide this month’s review of developments affecting private clients.

Oliver Marre

Oliver Marre (5 Stone Buildings) discusses the TOAA provisions in the light of the Fisher decision and asks: what should taxpayers do now to avoid penal income tax charges on offshore transfers?

Go to page of 2