While it was ten years at the end of October since Satoshi Nakamoto’s paper conceiving of Bitcoin as a peer-to-peer electronic cash system, it was only in mid-2017 that Bitcoin and other cryptocurrencies became mainstream. Many accountants will be grappling with the implications of cryptocurrencies as they work to complete 
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UK Budget 2018 – Tax Changes & Tax Planning for 2019 & Beyond. Despite speculation that the Chancellor would announce further restrictions to pensions tax relief, and fears that Entrepreneurs’ Relief might be scrapped, there were few surprises. More striking were the absences, with Brexit very much the elephant in 
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Domicile and The New Deemed Domicile Rules, HMRC Guidance & Notes The concept of domicile dates back to the Roman Empire and is generally described as a person’s permanent home. Although often referred to in a tax context, domicile is much broader and is rooted in private international law, which 
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Have your cake and keep your half penny – do not forget Substantial Shareholder Exemption (SSE) I was discussing the benefits of Substantial Shareholder Exemption (SSE) with a client the other day and found myself using one of my Gran’s favourite expressions – “you want your cake and to keep 
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Budget 2018: Change in Definition of Permanent Establishment & Amendments to Diverted Profits Tax Change in Definition of Permanent Establishment If an overseas business has a UK Permanent Establishment (PE), the profits of the business that are attributable to that PE, either directly or indirectly, are chargeable to UK tax. 
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In his 29 October 2018 Budget statement, Philip Hammond announced two important changes to the relief with wide-ranging consequences for shareholders who might otherwise have expected their prospective claims for Entrepreneurs’ Relief to be ‘in the bag’. Having been introduced ten years ago, the basics of Entrepreneurs’ Relief will be 
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Tax Disputes with HMRC In this article we take a look at how to progress matters when discussions with the inspector appear to have broken down or reached an impasse. Where agreement just cannot be reached between the taxpayer and HMRC the final outcome is the Tax Tribunal. However, the 
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IHT and DOTAS HMRC recently introduced a new “hallmark” to the Disclosure of Tax Avoidance Schemes (DoTAS) regime with a view to closing the inheritance tax avoidance gap. The scope of the new hallmark is very wide, and consequently any inheritance tax planning should be carefully considered in light of 
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Judicial Review and tax Introduction – Judicial review and tax The 2019 Loan Charge Action Group has launched a judicial review against HMRC in relation to the 2019 Loan Charge. In recent years, the courts have seen a sharp increase in judicial review against HMRC. In light of this, I 
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McLaren Racing Ltd v HMRC… The Tax Position on CTA 2009 s54; Fines, Penalties, Expenses & Business Profits Tax relief (or not) for fines Legislation (CTA 2009 s54) states that a company can deduct expenses that are wholly and exclusively for the purpose of the trade against their business profits. 
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