The following Tax practice note Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited provides comprehensive and up to date legal information covering:
Coronavirus (COVID-19): The Council of the EU has adopted a Directive amending the DAC to allow Member States to defer by up to 6 months automatic exchange of financial account information under DAC 2 and reportable cross-border tax planning arrangements under DAC 6. The amending directive also gives the Council the power to extend the deferral period by a further 3 months.
HMRC has stated in its International Manual that if a person cannot make a report in relation to financial account information under DAC 2 due to difficulties arising from the coronavirus pandemic, HMRC will accept that the person has reasonable excuse and will not levy a penalty for the late reports, provided it is made without unreasonable delay after the difficulties are resolved. For details on how HMRC is approaching the deferral of implementation of DAC 6 see Practice Note: Disclosable cross-border tax arrangements—DAC 6.
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an implementation period, during which it continues to be subject to EU law. This has an impact on this Practice Note. For further guidance, see Practice Note: Brexit—UK tax consequences.
In 2011, the European Council, comprising of the heads of state or government of
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When defendants are guilty, they have a choice to plead guilty or to put the prosecution to proof. When they plead guilty they may benefit from a reduction in their sentence as a result, see Practice Note: Credit for guilty plea. However, the Sentencing Council's overarching guidelines on reduction
Facilitating the performance of a duty by public officialsFacilitation payments, also known as facilitating or grease payments, are generally small amounts of money paid to public officials or others as a means of ensuring that they perform their duty, whether more promptly or at all. In some
What is a res judicata?A res judicata is a decision given by a judge or tribunal with jurisdiction over the cause of action and the parties, which disposes, with finality, of a matter decided so that it cannot be re-litigated by those bound by the judgment, except on appeal.Final judgments by
BREXIT: As of 31 January 2020, the UK is no longer an EU Member State, but has entered an implementation period during which it continues to be treated by the EU as a Member State for many purposes. As a third country, the UK can no longer participate in the EU’s political institutions, agencies,
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