Articles & Video
Complex offshore structures – traps and pitfalls: a practical guide
There has been a growing trend over recent years for the development of bespoke and complex holding structures to accommodate the needs and sensitivities of ultra-high net worth individuals. Often, the clients originate from civil law jurisdictions and as a consequence are unfamiliar with trusts and the fiduciary relationship created. There is (understandably) suspicion.
I can see clearly now…
In recent years, there has been a positive deluge of reporting initiatives affecting UK individuals, entities and structures with a UK connection. Some of these have come from the USA (so-called “FATCA”), some from the OECD (the Common Reporting Standard), others from the EU (as a result of the 4th Anti Money Laundering Directive) and others are simply ground-breaking initiatives by the UK government.
IHT & Non-UK Charities: Was the residue of an estate ‘given to charities’ for IHT purposes?
The Court of Appeal has confirmed that a legacy to non-UK charities did not qualify for the inheritance tax exemption in IHTA 1984 s.23 as it was not ‘given to charities’. The question of whether this interpretation complies with EU law was deferred to a later hearing
Tottenham Secures Win Against Hmrc Over Player Termination Fees
In Tottenham Hotspur Ltd v HMRC  UKFTT 0389 (TC), the First-tier Tribunal (FTT) has allowed the taxpayer's appeals and concluded that the transfer fees paid in respect of two football players were not payments made "from" the players’ employment and therefore were not subject to income tax or national insurance contributions (NICs) under section 9, Income Tax (Earnings and Pensions) Act 2003 and section 6, Social Security Contributions and Benefits Act 1992, respectively.