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CARELESSNESS


Adam Craggs and Tom Jenkins (RPC) examine the proposed criminal offence of making reckless untrue statements to HMRC and the concerns surrounding its scope and safeguards.
Mainpay should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
Several recent case decisions in the private client arena, including a challenge to the validity of the loan charge legislation, are examined by Edward Reed and Thomas Simpson (Macfarlanes).
In yet another IR35 case, a tribunal considers the procedural validity of the determinations under which HMRC sought to collect the tax.

John Hood answers a query for a reader whose client is under investigation by HMRC

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