HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos filed his tax returns on…
Council Directive (EU) 2018/822 (generally known as DAC 6) expressly provides for reporting obligations concerning cross-border arrangements that present an indication of a potential risk of tax…
In June 2017, the European Commission published its proposal on transparency rules for tax planning by intermediaries and certain taxpayers (the Commission proposal). The Commission proposal was…
On 16 April 2019, the European Parliament (EP) voted in favour of the proposed Directive on the protection of persons reporting on breaches of Union law (hereinafter "the Directive"). While the…
