Stephanie Mullins and Richard Jeens (Slaughter and May) explain how to take control of Sch 36 notices by engaging early with HMRC to narrow scope and responding strategically.
Parallel HMRC and civil proceedings are best handled not as two separate problems to be dealt with in sequence, but as a single, interconnected strategic challenge, write James Le Gallais and Anastasia Nourescu (Stewarts).
Legal advice privilege (LAP) remains a vital right for taxpayers, but its boundaries are far from settled. Jason Collins and Lauren Redhead (DLA Piper) examine LAP in a tax context, including the recent decision in Aabar v Glencore which extends privilege to intra-client group communications.
The starting point
Under Rule 27 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules, SI 2009/273 (as amended) (‘the FTT rules’), each party in standard or complex cases need only provide the other with a list of documents...
Heather Self (Blick Rothenberg) analyses HMRC’s latest tax gap figures, and explains why annual comparisons can mislead and why compliance activity alone will not close the gap.
In this month’s update, Tim Sarson (KPMG) tracks the EU Tax Omnibus and DAC recast proposals, Dutch Box 3 reform and digital services tax debate, noting the political barriers to implementation.
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