Tax evasion offences

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Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
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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19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Why have a tax covenant?It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May
Practice notes
SDLT group reliefFORTHCOMING CHANGE relating to FA 2008, Sch 36: In its Tax Information and Impact Note (TIIN) on freeports, the government announced...
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19th May

Most recent Tax evasion offences content

Practice notes
Failure to prevent the criminal facilitation of tax evasion—the offencesThis Practice Note discusses the two ‘failure to prevent’ corporate criminal...
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Produced in partnership with Rhys Meggy of QEB Hollis Whiteman 7th Sep
Practice notes
Enablers of offshore tax evasion—civil sanctionsIntroductionThe government’s strategy for tackling offshore tax evasion was initially set out in...
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Produced in partnership with Nicholas Griffin QC and Tom Broomfield of QEB Hollis Whiteman 6th Sep
Practice notes
Offshore tax evaders—criminal offencesBackground to the strict liability offences for offshore tax evadersThe government’s strategy for tackling...
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Produced in partnership with Nicholas Griffin QC and Tom Broomfield of QEB Hollis Whiteman 6th Sep
Practice notes
Criminal Finances Act 2017—progress through Parliament [Archived]ARCHIVED: This archived Practice Note is not being maintained. It tracked the passage...
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6th Sep
Practice notes
Offshore tax evaders—offshore penalties and other civil sanctionsThis Practice Note considers:•requirement to correct and failure to correct...
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Produced in partnership with Jason Collins of Pinsent Masons and Catherine Robins of Pinsent Masons 6th Sep
Practice notes
Offshore penalties, sanctions and criminal offences—outlineSTOP PRESS: The All-Party Parliamentary Group on Anti-Corruption & Responsible Tax, which...
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6th Sep
Q&As
Do you have a mutual anti-tax evasion facilitation clause for use in corporate transactional documents?The Criminal Finances Act 2017 (CFA 2017) came...
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16th Aug
Precedents
Anti-tax evasion facilitation clause—pro-customer1Anti-tax evasion facilitation1.1For the purposes of this clause 1:1.1.1the expressions ‘Associated...
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15th Aug
Practice notes
Failure to prevent facilitation of tax evasion—compliance issuesThe Criminal Finances Act 2017 (CFA 2017) introduced a corporate offence of failure to...
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15th Aug
Practice notes
Civil tax fraud investigations—Code of Practice 9Civil investigation of tax fraudHMRC’s published policy in respect of tax fraud states that HMRC will...
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Produced in partnership with Corker Binning 11th Aug
Practice notes
Cheating the public revenueOffence of cheating the public revenueThe offence of cheating the public revenue is a common law offence triable only on...
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11th Aug
Practice notes
Fraudulent evasion of income taxOffence of fraudulent evasion of income taxSection 106A of the Taxes Management Act 1970 (TMA 1970) provides that a...
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11th Aug
Practice notes
Fraudulent evasion of VATOffence of fraudulent evasion of VATIt is an offence under section 72(1) of the Value Added Tax Act 1994 (VATA 1994) if any...
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11th Aug

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