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Contentious tax: quarterly review

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The increased flow of information and data to HMRC under the common reporting standard (CRS) has prompted a flurry of so-called ‘nudge’ letters to be issued by HMRC to taxpayers whose offshore affairs it considers may not be in order. Additionally, HMRC has stated that the coronavirus job retention scheme (CJRS) may be a ‘magnet for fraudsters’ and is ramping up its efforts to clamp down on misuse. The High Court case of HMRC v IGE USA Investments Ltd & others may indicate that HMRC is adopting a more aggressive position with corporates where perceived avoidance is in play.

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