by John Kavanagh CTA ATT FRSA
<p>Hello, I am John Kavanagh, and this is the UK Tax Podcast, bringing you updates, information, and opinion about the most interesting topics and latest developments in UK tax. These podcasts are not intended as a substitute for professional advice, but hopefully, they will educate and entertain and give some useful pointers.</p>
Language
🇺🇲
Publishing Since
3/3/2025
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March 12, 2025
Send us a text In this episode of The UK Tax Podcast, John Kavanagh examines the rules regarding UK corporate tax residenceand the approach taken by HMRC. He explains the UK’s central management and control test, how HMRC has challenged offshore structures, and the role of double tax treaties in resolving residence disputes. The episode also explores the growing use of the mutual agreement procedure in modern treaties and touches on the relevance of permanent establishment rules for non-resid...
March 5, 2025
Send us a text In this episode of The UK Tax Podcast, John Kavanagh, Chartered Tax Adviser, examines the risks of distributions in a liquidation being taxed as income rather than capital under the Targeted Anti-Avoidance Rule (TAAR). With no binding case law and limited guidance from HMRC, this is a highly uncertain area, particularly where individuals resume similar business activities after a winding up. John explains how the TAAR operates, the importance of Conditions C and D, and why secu...
March 4, 2025
Send us a text In this episode of The UK Tax Podcast, John Kavanagh explores a significant recent decision from the Court of Appeal in the case of A Taxpayer v HMRC. The case considers how the Statutory Residence Test (SRT) deals with exceptional circumstances and when a taxpayer can be considered prevented from leaving the UK due to unforeseen personal events. The facts involve a taxpayer who exceeded the permitted days in the UK after stepping in to care for her sister during a serious hea...
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