Dominic Stuttaford (UK)

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Misuse of the furlough scheme: an emerging risk in M&A

More than one in four UK employees (over 9 million people) have been furloughed during the course of the Government’s Coronavirus Job Retention Scheme (the Scheme). HMRC considers that as much as £3.5 billion has been paid out in wrong or fraudulent claims and it has received over 20,000 reports of fraudulent furlough claims from … Continue Reading

First-Tier Tax Tribunal held that third party notices have extra-territorial effect

The First-Tier Tax Tribunal (FTT) has recently held that HMRC can issue third party information notices to non-UK residents under paragraph 2 of Schedule 36 to the Finance Act 2008 (Schedule 36). The FTT in Mr and Mrs PQ v HMRC[1] held that the residency status of individuals will not in itself determine HMRC’s ability … Continue Reading

HMRC final Guidance on Criminal Finances Act

The UK Government has published the final guidance on the new corporate offences of Failure to Prevent the Criminal Facilitation of Tax Evasion, contained in Part 3 of the Criminal Finances Act 2017, which will come into force on 30 September 2017. The Guidance is different from the draft guidance that was published in 2016, … Continue Reading

UK ILS framework moves ahead

HM Treasury has now published a formal consultation on legislation to implement a new regulatory, corporate and tax framework for insurance linked securities (“ILS”) business in the UK. This latest consultation follows the March 2016 initial consultation which sought feedback on the overall approach that the UK should take to develop a more competitive market … Continue Reading

UK embraces ILS structures

HM Treasury has now published a formal consultation in relation a new regulatory, corporate, insolvency and tax framework for insurance linked securities (“ILS”) business in the UK. The Government’s aim is to reinforce London’s standing as the world’s leading insurance market by creating the necessary legal environment to allow the domicile of ILS issuers in … Continue Reading
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