Law360, London: HMRC on 14 April 2025 established the penalty structure for financial institutions that fail to comply with the UK's regulations on automatic exchange of information (AEOI), including monetary penalties for late filing and inaccurate reports.
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Private Client analysis: This case principally concerned the exercise by HMRC of the power in section 684(7A)(b) of the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003), and its interaction with the Income Tax (Pay As You Earn) Regulations 2003 (the PAYE Regulations), SI 2003/2682. In
IHT—anti-avoidance provisionsThis Practice Note provides an overview of the main anti-avoidance measures that HMRC seek to rely on to prevent the avoidance of inheritance tax (IHT) in the UK. Note that the main body of the IHT rules is covered in several other Practice Notes. These are referenced
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Micklefield clausesWhat is a Micklefield clause?It is common for employee share plans to provide that, on termination of employment (or when an employee is given or receives notice of termination of employment), subsisting share awards will be forfeited and subsisting share options will lapse.It is
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