Tax evasion offences

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Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Tax evasion offences content

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
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
ARCHIVED: This archived Practice Note is not being maintained. It tracked the passage of the Bill through Parliament to its publication as an Act, and...
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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
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
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
Offence of fraudulent evasion of income taxSection 106A of the Taxes Management Act 1970 (TMA 1970) provides that a person commits an offence if they...
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9th Apr
Practice notes
Civil investigation of tax fraudHMRC’s published policy in respect of tax fraud states that HMRC will seek to use a civil rather than criminal...
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Produced in partnership with Corker Binning 26th Feb
Practice notes
Offence of cheating the public revenueThe offence of cheating the public revenue is a common law offence triable only on indictment. This means that,...
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26th Feb
Practice notes
The Criminal Finances Act 2017 (CFA 2017) introduced a corporate offence of failure to prevent facilitation of tax evasion, which came into force on...
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24th Feb
Q&As
The Criminal Finances Act 2017 (CFA 2017) came into force on 30 September 2017 and introduced into English law a new corporate offence of failure to...
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15th Feb
Precedents
1Anti-tax evasion facilitation1.1For the purposes of this clause 1:1.1.1the expressions ‘Associated With’, ‘Prevention Procedures’, ‘UK Tax Evasion...
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14th Feb

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