Penalties, interest and time limits

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Practice notes
Offshore income gains (OIGs) are gains realised on the disposal of interests in offshore funds which are either:•non-distributor offshore funds, or...
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9th Nov
Practice notes
The issue of sham is most likely to be raised by the settlor's creditors or former spouse if the settlor is involved in matrimonial proceedings, who...
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9th Nov
Practice notes
A trust is formed either by lifetime gift or on death when a person (the settlor) transfers assets to another person or persons (the trustees) to hold...
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Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan
Practice notes
When trustees are engaged in trust litigation, issues often arise as to how their litigation costs are to be funded. A Beddoe application is the best...
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Produced in partnership with Kate Davenport QC of Outer Temple Chambers and Adele Isaacs of Bankside Chambers 12th Jan
Practice notes
This Practice Note outlines Bermuda trust law and focuses upon its unique features and recent reforms, such as Bermuda's regime for private trust...
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Produced in partnership with Vanessa Lovell Schrum and Caljonah Smith of Appleby, Bermuda 12th Jan
Practice notes
This Practice Note provides guidance on Cayman Islands STAR trusts. For general information about the Cayman Islands, see Practice Note: Private...
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Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan
Practice notes
Trust litigation has been classified as being of three types:•a dispute as to the trusts on which trustees hold the subject matter of the settlement•a...
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9th Nov
Practice notes
Where a beneficiary either:•is a minor (ie under the age of 18) and unmarried or•has attained majority or has married under that date but is required...
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9th Nov
Practice notes
Duration of a trustThe duration of an express trust is subject to the restrictions imposed by the rules against remoteness of vesting and against the...
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9th Nov
Practice notes
Duty to distribute to the correct beneficiariesOn the termination of the trust, the trustees are under a duty to distribute the trust assets to the...
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9th Nov
Precedents
This Deed of Appointment is made on [date] by [trustee] of [address] and [trustee] of [address] (the Trustees).Background(A)This Deed is supplemental...
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9th Nov
Practice notes
When you advise an individual on cross-border issues or offshore tax planning, it is important to establish the 'situs' (ie location) of the assets...
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9th Nov
Precedents
This partial deed of revocation is made on [date] by [donor] of [address].1I granted a Lasting Power of Attorney for [Financial Decisions/Health and...
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9th Nov
Practice notes
Liferent trustsA liferent trust (or trust liferent) is a trust which, when settled, confers a use and income benefit, or both, in the trust property...
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Produced in partnership with Peter Murrin of Turcan Connell 12th Jan
Practice notes
An offshore trust is any non-UK resident trust. The liability of trustees of an offshore trust to UK inheritance tax (IHT) is not dependent on the...
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Produced in partnership with Jenny Wilson-Smith and Emma Haley of Boodle Hatfield 12th Jan
Practice notes
Express creation of trustsA trust is constituted expressly where the owner of property (the truster) transfers property to trustees to hold for...
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Produced in partnership with Yvonne Evans, Law Lecturer, Solicitor (non-practising), TEP, University of Dundee 12th Jan

Most recent Penalties, interest and time limits content

Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
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9th Apr
Practice notes
A taxpayer will not be liable for a penalty for late payment of tax if they have a reasonable excuse for failing to comply with the legislation. For...
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Produced in partnership with Philip Rutherford 9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
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Produced in partnership with Philip Rutherford 9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
Read More >
Produced in partnership with Philip Rutherford 9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
Read More >
Produced in partnership with Philip Rutherford 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
Read More >
Produced in partnership with Philip Rutherford 9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
Read More >
Produced in partnership with Philip Rutherford 9th Apr
Practice notes
FORTHCOMING CHANGE: HMRC has consulted on proposals to amend the rules in Schedule 41 to the Finance Act 2008 on penalties for failure to notify, as...
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Produced in partnership with Philip Rutherford 9th Apr
Practice notes
FORTHCOMING CHANGE: HMRC has consulted on proposals to amend the rules in Schedule 41 to the Finance Act 2008 on penalties for failure to notify, as...
Read More >
Produced in partnership with Philip Rutherford 9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
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Produced in partnership with Philip Rutherford 9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained. HMRC has the power to charge a penalty where there are errors in, or omissions...
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Produced in partnership with Philip Rutherford 9th Apr
Practice notes
STOP PRESS: The All-Party Parliamentary Group on Anti-Corruption & Responsible Tax, which was established in June 2020 is currently researching more...
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9th Apr
Practice notes
What is the requirement to correct?The legislation for the requirement to correct (RTC) regime is set out in section 67 and Schedule 18 to the Finance...
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9th Apr
Practice notes
This Practice Note considers:•requirement to correct and failure to correct penalties•penalties for offshore matters or offshore transfers•offshore...
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Produced in partnership with Jason Collins and Catherine Robins of Pinsent Masons 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Nicholas Griffin QC and Tom Broomfield of QEB Hollis Whiteman 9th Apr
Practice notes
IntroductionThe government’s strategy for tackling offshore tax evasion was initially set out in HMRC’s 2014 No Safe Havens and has been supplemented...
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Produced in partnership with Nicholas Griffin QC and Tom Broomfield of QEB Hollis Whiteman 9th Apr
Practice notes
This Practice Note discusses the two ‘failure to prevent’ corporate criminal offences created by the Criminal Finances Act 2017 (CFA 2017):•CFA 2017,...
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Produced in partnership with Rhys Meggy of QEB Hollis Whiteman 9th Apr
Practice notes
This Practice Note is about the penalty regime in the Finance Act 2009 (FA 2009) for the late payment of:•income tax and Class 1 NICs via pay as you...
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Produced in partnership with Philip Rutherford 8th Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 contains a number of measures, taking effect from Royal Assent, to take further action against those who...
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26th Mar

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