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Non-UK Residency - Tribunal Relieves Taxpayer of £3 Million Tax Demand

Claims to non-UK residency for tax purposes are a political and fiscal hot potato and HM Revenue and Customs (HMRC) are, to say the least, reluctant to accept them. In an exceptional case, however, the First-tier Tribunal (FTT) backed a hard-pressed...

Entrepreneurs' Relief and the Definition of 'Trade' - Guideline Ruling

At what point can it be said that an embryonic business has begun to trade? A tax tribunal pondered that fundamental issue in a case concerning a claim for entrepreneurs' relief on the sale of a nascent business asset. An investor sold his minority stake...

Performance of Employment Contract 'Tainted by Illegality' - Cautionary Tale

There is nothing wrong with an employee being paid in a tax-efficient manner. As an Employment Tribunal (ET) ruling showed, however, where such arrangements stray into the realms of unlawful evasion the consequences are likely to be severe. The case...

Double Taxation Treaties - Wealthy South African Relieved of £10 Million Bill

Rich individuals often have their feet firmly planted in more than one country and that can give rise to disputes as to where they should be taxed. In a guideline case, the First-tier Tribunal (FTT) considered the position of an extremely wealthy man with...

What are the Tax Implications of Settling an Employment Tribunal Claim?

When paying money to settle Employment Tribunal (ET) proceedings, employers are not infrequently motivated by a desire to make what they perceive as a nuisance go away – but how should such payments be treated for tax purposes? The First-tier Tribunal...

Private Dog Grooming Tutor Denied VAT Exemption

The categories of business that enjoy VAT exemption are highly restricted and any attempt to extend them is likely to encounter stiff opposition from HM Revenue and Customs (HMRC). That was certainly so in the case of a woman who provided private tuition in...

Donating Shares to Charity - Tax Tribunal Resolves Valuation Impasse

It makes perfect sense that the market value of shares given to charity is deductible from the donor's tax liabilities. However, as an important tax tribunal ruling showed , discerning exactly what that value is can be very far from straightforward. The...

Tax Ruling - TV Presenter's Personal Service Company Falls Foul of IR35

Media personalities, IT professionals and others often obtain perfectly legitimate tax advantages by providing their services as independent contractors via their own private companies. As one case showed, however, the tax authorities are making...

Director Held Personally Liable for Multi-Million-Pound Missing Trader Fraud

Where a company becomes involved in the fraudulent evasion of tax, the corporate veil will rarely protect its directors from personal liability. An elderly businessman found that out to his cost when he received a seven-figure bill that was likely to...

Tax Avoidance Schemes, No Matter How Intricate, May Not Be Effective

There is nothing unlawful about tax avoidance schemes but, however intricate and apparently foolproof they may be, their effectiveness can never be guaranteed. A businessman found that out to his cost after one such scheme failed to shield him from a...
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