TAX RISK

A report by Lexis®+UK Tax

Ruby Hamid

The new fraud offence is a notable expansion of the failure to prevent (FTP) model creating corporate criminal liability. Ruby Hamid and Nicholas Gardner (Ashurst) examine actions for companies, and compare the rules with the existing FTP offences for bribery and tax evasion.

Kyle Rainsford

Victoria Hine

Kyle Rainsford and Victoria Hine (Addleshaw Goddard) examine what is believed to be the first case which has applied the iniquity principle in relation to tax advice.

Frankie Beetham

Ceinwen Rees

The newly reformed tax on carried interest will subject carried interest to the payments on account regime. Ceinwen Rees and Frankie Beetham (Kirkland & Ellis) set out some of the key practical considerations.

Laura Foley

Tom Cartwright

Laura Foley and Tom Cartwright (Certa Insurance Partners) share insights on the insurer’s perspective when underwriting tax risks, and the impact on policy structure.

Arthur Wong

Ben Elliott

The recent cases of Bhaur and JTC illustrate the opportunities and challenges for taxpayers who have misunderstood the tax consequences of a transaction, write Ben Elliott and Arthur Wong (Pump Court Tax Chambers).

Laura Foley

Tom Cartwright

The taxation of insurance proceeds is relevant for sizing a policy limit. Laura Foley and Tom Cartwright (Certa Insurance) consider various practical scenarios and implications.

Ben Jones Jannine Nicholas Helen Mackey

Ben Jones, Helen Mackey and Jannine Nicholas (Eversheds Sutherland) explain how to obtain and maximise the benefits of tax risk insurance.

Constantine Christofi

Adam Craggs

Whilst taking professional advice will usually mean a taxpayer has taken reasonable care, not taking advice does not necessarily mean a taxpayer has been careless, write Adam Craggs and Constantine Christofi (RPC).