Author Archives: Dr Stephen Daly

The non-dom rule, a relic of the British Empire, appears all but set to go. In brief, the rule provides that non-domiciled individuals pay tax only on income earned in the UK and to pay on a remittance basis for … Continue reading →

Introduction Having commented last week on the case of Ingenious Media, it is appropriate now to briefly revisit this case, given that the Court of Appeal on Wednesday unanimously dismissed the appeal by the taxpayers. There is one particular aspect … Continue reading →

In recent days, I’ve been reading back over my Jurisprudence notes in order to understand the place of law in achieving administrative justice-does the answer lie in structuring rules, or in providing discretion, or finding a balance between law, rules … Continue reading →

HMRC is certainly taking a hammering these days. Those in the twittersphere have questioned their modus operandi and the press has hounded the public authority for failing to prosecute more Swiss bank account holders. Both the Treasury Select Committee and Public … Continue reading →

A INTRODUCTION Global headlines have been caught by the release of data detailing the facilitation of tax dodging, likely evasion,[1] by the Swiss branch of HSBC. There is in reality nothing new about the revelations-the ‘Lagarde List’ has been blowing … Continue reading →

Yesterday at the OUCBT conference on Diverted Profits tax (‘DPT’), the ‘respondents’ on behalf of the government (Philip Baker QC and Mike Williams of the Treasury) were quick to point out that the DPT was aimed at contrived, artificial arrangements. … Continue reading →

Some commentators have been apocalyptic about the introduction of Advanced Payment Notices (‘APNs’). The APN regime broadly requires that taxpayers pay disputed tax upfront, before being able to challenge HMRC’s assessment through the normal channels. It is certainly ‘game changing’ … Continue reading →

There is likely to be much written on the blogosphere and in newspapers over the next few days dissecting George Osborne’s 50 minute-long Autumn Statement. Rather than attempting to extensively cover it, I just seek here to tease out a … Continue reading →

1. Introduction This piece was originally posted on Joylon Maugham’s blog (waitingfortax.com) on 13 November 2014. It is reproduced here with permission. The recent debate on tax in the UK has strayed into the murky area of questioning the relevance … Continue reading →

Discourse is essential to fostering change. But discourse is not groups of people talking past each other; nor is it commentators using the same language, but according words differing interpretations to suit their argument. For discourse to foster change, it … Continue reading →