
Dion Seymour comments on the UK government’s call for voluntary disclosure of crypto
Dion Seymour comments on the UK government’s call for crypto users to voluntarily disclose any unpaid capital gains or income taxes, in CoinDesk.

Miles Dean comments on the implications of removing the non-domiciled tax status
Head of International Tax, Miles Dean, comments on the implications of the Labour Party’s pledge to scrap the non-domiciled tax status, in the Financial Times.

Double Tax Treaties: An ex-Insider’s View of HMRC’s Treaty Position – Andrew Parkes
During my time at HMRC, I worked with the Tax Treaty team on the two Bank Levy Double Taxation Relief treaties and delivered training to HMRC staff on the UK’s treaties generally. Interestingly, HMRC does have its own model treaty, but this is not published. It is, however, closely modelled on the OECD model convention. […]

The Taxman Cometh – Soon – Andrew Parkes
We have mentioned previously (see our January 2022 Newsletter) that the UK will seek to tax any income from a trade carried on in the UK by a non-resident, but that this is blunted where there is a Double Taxation Agreement (DTA) between the UK and the country of residence of the trader. Where there […]

The Paradox of Tax Planning and Morality: A review of Taxpayer v HMRC – Chimezirim Echendu
Introduction In Finance Act 2013, the UK introduced a statutory residence test (SRT) to provide an objective way of determining the residence of individuals. The test, although based substantially on day counting and days spent in the UK, also relies on the substance and quality of an individual’s residence to determine tax residence. As days […]

But why? – Not the cry of every toddler, but why a relief is due – Andrew Parkes
One of the real joys (and I’m not being sarcastic here) of working in International Tax is that what seems to be the simplest of questions can have the most hidden of answers. The UK’s distribution exemption (i.e. dividends received from underlying subsidiaries are exempt from UK taxation) for small companies is only available where […]

US Taxpayers Saving for Retirement – Mike Haynes
Head of Employment and Pensions Mike Haynes discusses how US taxpayers can save for retirement in the UK while avoiding common associated problems.

The standards are coming! The standards are coming! – Zoe Wyatt and Dion Seymour
Zoe Wyatt and Dion Seymour, discuss the global implications of new US crypto tax reporting rules, in Bloomberg Tax.

Andrew Parkes interviewed by Bloomsbury Professional
National Technical Director, Tax, Andrew Parkes, discusses the evolution of International Tax during his career and the major challenges the industry is facing at the moment, in an interview with Bloomsbury Professional.
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