APNS

Barrister Michael Thomas (Pump Court Tax Chambers) believes there is a disturbing trend in our tax jurisprudence: an increasing number of important decisions made by HMRC are only capable of being challenged on a judicial review basis.

Tracey Bowler

Current taxpayer safeguards for HMRC’s notice powers are neither independent nor accessible, writes Tracey Bowler (Institute for Fiscal Studies).

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) examine the judgment and consider where this leaves us.

Zoe Andrews

Jeanette Zaman

Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.

Zoe Andrews

Jeanette Zaman

Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.

Gideon Sanitt

In Pitcher, the tribunal has considered HMRC’s entitlement to issue a penalty following non-payment of an accelerated payment notice. Gideon Sanitt (Macfarlanes) reviews the impact of that decision.

Patrick Cannon

Taxpayers should question their legal advisers carefully about bringing future challenges to the accelerated payment notices regime if they are not to throw good money after bad. Patrick Cannon (15 Old Square) reviews the four reported judicial review challenges to APNs of note.

Chris Davidson

Chris Davidson (KPMG) believes that HMRC has misinterpreted the 2004 DOTAS rules by issuing APNs on the basis that they are substantially the same as a previous transaction that was notifiable under DOTAS.