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Carelessness
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Carelessness
CARELESSNESS
Reckless tax statements: a lower threshold for crime?
Adam Craggs
Tom Jenkins
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.
Rebel without a causal link: HMRC’s position on proving carelessness
Sophie Rhind
Victoria Braid
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).
Private client review for January 2022
Thomas Simpson
Edward Reed
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).
Another day, another BBC IR35 case: with a sting in the tail
David Whiscombe
In yet another IR35 case, a tribunal considers the procedural validity of the determinations under which HMRC sought to collect the tax.
Ask an expert: Carelessness and the new penalty regime
John Hood
John Hood answers a query for a reader whose client is under investigation by HMRC
EDITOR'S PICK
ScottishPower and penalties: McKnight sent off
Rupert Shiers
,
Katharine Crossman
1 /7
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
2 /7
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
,
Martin Verrall
3 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
4 /7
The Orsted ‘tax nothing’
Andrew Page
5 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
6 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
7 /7
ScottishPower and penalties: McKnight sent off
Rupert Shiers
,
Katharine Crossman
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
NEWS
Read all
Finance Bill 2027 published: key measures
International Controlled Transaction Reporting Regulations published
Tax treatment of image rights payments: new draft guidance
SAYE bonus rates increased
ADT: Highlands and Islands exemption
CASES
Read all
Hogan Lovells Cadwalader International LLP v HMRC
HMRC v The Mersey Docks and Harbour Company Ltd
Bottled Science Ltd v HMRC
R (Thomas Holdings Ltd and others) v HMRC
Another case that caught our eye: 13 November 2026
IN BRIEF
Read all
Employees’ expenses
Closing the tax gap: what should taxpayers expect?
Interest withholding tax: a partial solution
Founders’ Relief
Distributions reform: unresolved questions
MOST READ
Read all
Founders’ Relief: a narrow route to 10%
Tax Journal's 2026 Budget coverage
New HMRC withholding tax guidance
Budget 2026: Sovereign immunity - a more considered reform
Distributions reform: unresolved questions