Mark Cawthron

Mark Cawthron

Mark Cawthron LLB CTA is a tax writer at Croner-i Tax and Accounting, part of Croner-i Ltd, specialising in UK corporate taxation (including international), employee share incentives and stamp taxes. He is a tax lawyer by background, a solicitor, and member, by examination (CTA), of the Chartered Institute of Taxation (CIOT).

Tax / Real estate gains and tax liability via offshore CIVs

Changes to tax rules will see UK real estate gains of offshore collective investment vehicles (CIVs) face new tax charges, but there are some exemptions so it is not all bad news for investors. Mark Cawthron LLB CTA explains 

Tax / OECD makes progress on improving international tax transparency

The OECD Secretary-General Tax Report to G20 Leaders provides a concise and upbeat summary of the dramatic changes to the international tax environment over the past 10 years, Mark Cawthron examines the key issues

Tax / What you need to know: diverted profits tax – part 3

In the final part of our series on the diverted profits tax (DPT), Mark Cawthron LLB CTA, tax writer at Croner-i, assesses how Finance Act 2019 changed the DPT rules and use of the profit diversion compliance facility

Tax / What you need to know: diverted profits tax – part 2

In the second of a three part series on the diverted profits tax (DPT), Mark Cawthron LLB CTA, tax writer at Croner-i considers recent developments from UK implementation to interaction with OECD Base Erosion and Profit Shifting (BEPS) rules

Tax / What you need to know: diverted profits tax – part 1

In the first of a three part series on the diverted profits tax (DPT), Mark Cawthron LLB CTA, tax writer at Croner-I considers whether it has acted as a deterrent to multinationals attempting to mitigate their tax bills and compliance issues

Tax / ‘Off-plan’ purchases and capital gains tax post-Higgins

Mark Cawthron, tax writer at Croner-i, looks at how prospective purchasers of flats off-plan, and developers offering such flats, might think about reacting to the decision in the recent case of Higgins, with a view to seeking to mitigate or remove such difficulty

Tax / OECD progresses on BEPS anti avoidance measures

Mark Cawthron LLB CTA, tax specialist at Croner-i, examines the developments in the OECD’s framework package on base erosion and profit shifting (BEPS) over the 12 months to June 2018 and the progress that has been made in the UK's approach to the 'digital challenge'

Tax / Supreme Court flexes powers over interest in Prudential case

In Prudential Assurance Company Ltd v R & C Commrs [2018] BTC 31, the taxpayer sought (among other claims) restitution of an amount calculated as compound, and not simple, interest but the Supreme Court, in its judgment delivered in July 2018, rejected this claim. Mark Cawthron LLB CTA examines the judgment

Tax / IR35: extending rules to the private sector

Mark Cawthron LLB CTA, tax writer at Croner-i, examines the fallout from government plans to extend IR35 intermediary rules to the private sector companies, examining the contradictory rulings at tribunal in the cases of Christa Ackroyd, MDCM and Jensal Software

Tax / IR35 tax tribunal rulings on so-called disguised employment

Mark Cawthron LLB CTA, tax writer at Croner-i Tax & Accounting, considers the implications of the recent MDCM ruling in favour of the appellant in an IR35 case on so-called 'disguised employment' in light of the contrary decision in the recent Ackroyd BBC case

Tax / Tax overhaul for overseas investors in UK real estate

Mark Cawthron LLB CTA, specialist tax writer at Croner-i, examines the plans to tax non-resident investors in UK real estate with the extensions of non-resident capital gains tax liability to companies from April 2019

Tax / Budget 2017: rather more than first meets the eye

Mark Cawthron LLB CTA assesses the first autumn Budget in 20 years, outlining the key measures and stressing that a far from radical Budget actually disguised a number of significant tax measures 

Tax / Disguised employment: tax compliance for freelance workers

Mark Cawthron LLB CTA examines the ins and outs of disguised employment, running through some key aspects of the existing tax rules and picks up on a recent tribunal case, Big Bad Wolff Ltd [2017] TC 06143

Tax / Returning expatriates – what should we do with our UK house?

Mark Cawthron LLB CTA, tax writer at CCH Online considers the potential tax traps for expatriates intending to return to the UK and considers how they might seek to deal with UK residential property they have long held, and which is showing healthy gains

Tax / Partnership taxation: chargeable tax and profit allocations

The imminent overhaul of tax rules for all types of partnerships will have a wide-reaching impact, particularly on the bare trust/beneficiary approach. Mark Cawthron LLB CTA outines the key changes and sets out potential pitfalls for partners to consider
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