Joseph Hage Aaronson & Bremen LLP

Establishing POEM for overseas trusts – Haworth & Ors v HMRC

In this article, Helen McGhee and Megan Durnford discuss the case of Haworth & Ors v HMRC [2025] EWCA Civ 822 which confirms that an appropriately broad test should be used for the purpose of establishing the place of effective management (“POEM”) of a trust as required by many double tax treaties.

Double Remittance Amended Legislation

Helen McGhee explores the impact on ‘re-remittance’ of foreign income and gains as a result of the changes implemented by the Finance Act 2025 .

HMRC’s new “US-style” whistleblowing scheme announced

Harry Harper explores plans for HMRC to introduce a new whistleblowing scheme inspired by those used in the United States and Canada

Search and Seizure

Helen McGhee TEP, Elizabeth Dean and Megan Durnford consider HMRC’s ever-expanding criminal investigation powers.

UT considers taxpayer’s application for permanent anonymity and third-party disclosure request

The Upper Tribunal (UT) rejected a taxpayer’s application for permanent anonymity, following the taxpayer's decision to withdraw their substantive appeal with the First-tier Tax Tribunal (FTT). The UT further granted a third party limited access to the FTT’s previous case management decision.

The End of the Remittance Basis and the Two Transitional Provisions

Tax year 2024/25 (the current year) marks the last year that eligible individuals will be able to make a remittance basis claim. From 2025/26 the remittance basis will be replaced with the 4-year FIG regime. Helen McGhee and Lynnette Bober explore the impacts of this change.

Review of Anti-Avoidance Legislation

Lynnette Bober and Helen McGhee summarise the anti-avoidance provisions now under review.

Private Client Budget Update

Helen McGhee and Lynnette Bober reflect on the Autumn Budget and its impact on Private Clients.

Budget Speculation

With the highly-anticipated Budget due to be delivered on 30 October 2024, Helen McGhee and Lynnette Bober's latest article explores how this event is likely to impact taxpayers.

The Proposed Changes to Domicle - A Fundamental Rethink is Required

Ahead of the upcoming Budget, Helen McGhee and Lynnette Bober set out their concerns surrounding the proposed changes to the domicile regime and their recommended approach to the reforms.

Changes to the UK's Special Tax Regime for Foreign Income and Gains

With much uncertainty surrounding the end to the non-domicile regime, Helen McGhee and Lynnette Bober provide a helpful summary of the (currently) anticipated changes.

The End is Nigh for the Non-Dom Regime

Published in ThoughtLeaders4 Private Client Magazine, Helen McGhee expert analysis of the current state of non-dom tax regime and it's future.

HMRC Makes Changes to COP9

On 14 June 2023, HMRC published a substantially rewritten Code of Practice 9 (“COP9”). Helen McGhee and Megan Durnford set out the key changes implemented as a result of this publication.

Pandora Papers: HMRC issues nudge letters

Helen McGhee sets out HMRC's response to the Pandora Papers leak of almost 12 million documents

Increased Investment in Personal Tax Compliance in the UK

Helen McGhee discusses the main developments in support of the increased focus on international transparency and personal tax compliance in the UK.

Tax-Related Measures in the Autumn Statement 2022

This article explores the tax measures included in the Autumn Statement 2022

Offshore Structures and Onward Gifts

This article explores the "onward gift" tax anti-avoidance rules introduced by the Finance Act 2018.

Increased Investment in Personal Tax Compliance in the UK

This article discusses the main developments in support of the increased focus on international transparency and tax compliance in the UK.

Case note: Lynton Exports (Alsager) Ltd v Revenue and Customs Commissioners [2022] UKFTT 00224 (TC)

JHA’s latest insight into the First-tier Tribunal’s decision in Lynton Exports (Alsager) Ltd v Revenue and Customs Commissioners [2022] UKFTT 00224 (TC).

What is domicile and why does it matter for tax?

A quick review of the fundamental principle of domicile, why it matters for tax, and what the current political landscape has in store.

Tax note: Financial Institution Notices (FIN)

Understanding paragraph 4A of Schedule 36 to the Finance Act 2008

FTT Decision on Excise Duty in Cantina Levorato SRL v HMRC [2021] UKFTT 461 (TC)

A Short Case Report on the FTT decision in Cantina Levorato SRL v HMRC [2021] UKFTT 461 (TC)

Fast Track for Register of Overseas Entities Owning UK Property

The invasion of Ukraine has prompted the UK government to speedily publish the draft legislation for the Economic Crime (Transparency and Enforcement) Bill 2022.

Global Minimum Tax on Corporations: OECD GloBE Model Rules and their implementation in the UK

On 8 October 2021, the OECD/G20 published a statement confirming that 136 jurisdictions had agreed to a two-pillar solution to address the tax challenges that arise from the digitalisation of the economy and setting out an implementation plan.

‘MTIC’ Fraud – Kittel Test PTGI International Carrier Service Limited v. HMRC [2022] UKFTT 20 (TC)

A summary of the FTT decision in PTGI International Carrier Service Limited v. HMRC [2022] UKFTT 20 (TC)

HMRC consultation on the OECD mandatory disclosure rules

HMRC has published a consultation on draft regulations to implement the Organisation for Economic Cooperation and Development (OECD) rules on mandatory disclosure of certain avoidance arrangements. Helen McGhee explains the background to the new rules and their implications.

Post-Prudential: Decision released by the FTT

On 8 December 2021, judgment in the Post Prudential Group Litigation was handed down by the First-tier Tribunal (Tax Chamber) (“FTT”).

S&S Consulting Services (UK) Ltd v HMRC: Can a company be re-registered for VAT pending appeal?

On 26 November 2021, the High Court of Justice issued its judgment in S&S Consulting Services (UK) Ltd, R (On the Application Of) v HM Revenue and Customs [2021] EWHC 3174

VAT De-registration: the CJEU decision in the Promexor case

On 18 November 2021, the Court of Justice of the European Union (the “CJEU”) delivered its judgment in Case C-385/20 (Promexor Trade SRL v Directia Generala a Finantelor Publice Cluj – Administratia Judeteana a Finantelor Publice Bihor).

FICkle fortunes

Helen McGhee discusses the use of corporate vehicles in family wealth and succession planning in the UK