News

October 20th, 2023

HMRC Magic Carpets ride ends in bumpy landing…

Magic Carpets: Introduction   One Thousand and One Nights or, as commonly known, The Arabian Nights is a collection of Middle Eastern folk tales originally compiled in the Arabic language, but translated into many different languages since.   If a tax story had ever been considered for the Arabian Nights then one would have to […]

October 4th, 2023

Portugal NHR tax changes: Portugal… no longer the man?

Portugal NHR tax changes – Introduction   Portugal, known for its stunning landscapes and welcoming atmosphere, has been a magnet for foreign individuals seeking a new place to call home. However, amongst the many attractions, the Non-Habitual Resident (NHR) regime has stood out for several several years as an area of outstanding financial beauty. I […]

September 29th, 2023

In a policy unit far, far away…

IHT – a new hope?   Back in 2014/15, I baffled an audience in Hong Kong by explaining that Star Wars was all about a dispute over taxes*.   To be fair, I was supposed to be talking about the changes to UK property taxes that had been announced over recent years (ATED, 15% super-rate […]

September 23rd, 2023

HMRC v Bluecrest Capital Management: HMRC tripping on the Bluecrest of a wave

Introduction   The Upper Tribunal (UT) recently delivered its verdict in HMRC V Bluecrest Capital Management (UK) LLP.   In doing so, it upheld the decision of the First-tier Tribunal (FTT).   The case is an important one as it one of the first to considers the application of the salaried members rules, introduced in […]

September 16th, 2023

Is it really the worst tax avoidance scheme of all time?

Introduction There has been some commentary on social media over the last week around whether a particular variant of property incorporation is ‘the worst tax avoidance scheme of all time?” So, is it? Now, I think I could win this argument quickly. I would simply point to NT Advisers Working Wheels scheme. But that would […]