Private client review for October

Posted on 28 October 2019

Speed read: In Rialas, HMRC failed in its attempt to invoke the transfer of assets abroad rules and impose an income tax charge on dividend income payable to a non-resident company. There was a controversial decision by the FTT in Cliff, where it found that deliberate conduct need not be accompanied by an intention to make a false claim; this goes against the accepted behavioural distinctions for penalties (careless, deliberate and behaviour which is both deliberate and concealed). In ABC and others, trustees were successful in their application for rectification of a trust instrument on the ground of mistake where the unintended effect of the instrument was both immediate and future IHT liabilities and where HMRC chose not to interpose. Paya Ltd and others is the latest in IR35 cases brought against television presenters and whilst HMRC prevailed in claiming that all three presenters were employees of the BBC, it failed to extend time limits for determinations on the basis of careless behaviour.

Read the full article here.

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