UK corporate offence of failure to prevent tax evasion
Businesses in the blockchain and cryptoasset space are increasingly looking to utilise digital currency and other cryptoassets as an alternative to or alongside other, more traditional employee incentive arrangements, such as...more
Welcome to June’s edition of our UK Tax Round Up. Several interesting cases have been reported this month, including a range of issues relevant to UK withholding tax on interest being considered in Hargreaves. HMRC has also...more
In the summer of 2022, the UK government consulted on extending the scope of the UK Investment Manager Exemption (the “UK IME”) to include direct transactions in cryptoassets. Our previous OnPoint on the consultation,...more
As part of the Edinburgh Reforms announced by the UK Government (link back to “UK FS Reforms”), the UK Government has also confirmed that the “Investment Transactions List” (“ITL”) would be expanded to include cryptoassets....more
In yet another development for the UK cryptocurrency sector, on 5 July 2022 the UK Government announced a consultation as to the taxation of cryptoasset loans and “staking” within the context of decentralised finance...more
As part of wider efforts to make Britain a global hub for cryptoassets technology and investment, on 4 April 2022 the government publicly committed to consult on extending the scope of the UK Investment Manager Exemption (the...more
In early February, HMRC published a new chapter in its Cryptoassets Manual dealing with decentralised finance (“DeFi”). DeFi is an umbrella term encompassing a range of products which are comparable with traditional financial...more
One driver for the first widely adopted cryptocurrency Bitcoin was to create a store of value that existed outside of government control. It is therefore no surprise that attempts to regulate the rapidly developing crypto...more
With a number of changes affecting the private wealth world to come over the next 12 months, our private client team take a look at some of the key UK legal developments for 2020, including the extension of the UK trust...more
On 20 December 2019 HMRC updated its guidance on the taxation of cryptoassets. In particular, HMRC has now given its view on where the most common form of cryptoasset (being the exchange token) should be treated as located...more
UK Case Developments - IR35 – no mutuality of obligation to create a contract of employment - RALC Consulting Ltd v HMRC has provided the First-tier Tribunal (FTT) with another opportunity to consider the application...more
UK Case Law Developments - More decisions on IR35 - This month has seen two more decisions on whether broadcast presenters providing their services to the BBC and ITV respectively would or would not have been...more
HMRC confirms that cryptoassets are not considered to be money or currency for tax purposes. On 1 November 2019, HM Revenue & Customs (HMRC) issued a policy paper on the taxation of cryptoassets for businesses and...more