DOTAS

Malcolm Gammie CBE KC (One Essex Court) examines recent Government proposals which, he says, leave little doubt that tax avoidance, like tax evasion, is to be regarded as a criminal activity.

No deduction allowable for provisions in respect of an unfunded unapproved retirement benefit scheme, Court of Appeal rules

FTT imposes maximum £1m DOTAS penalty for failure to notify

Ramsay argument fails to save taxpayer from £10m tax assessment

FTT considers meaning of ‘promoter’ in DOTAS regime.

Interest calculation on restitutionary payment: Test claimants in the franked investment income group litigation v HMRC [2024] EWHC 1671 (Ch) (18 June 2024) is another episode in the saga of the compatibility of the UK’s regime for the taxation...

Andrew Parkes

Andrew Parkes (Andersen) considers the limits, if any, on the introduction of retrospective legislation.

Discovery assessment on pension scheme charges upheld: L Trachtenberg v HMRC [2024] UKFTT 376 (TC) (9 May) involves another challenge to the scope of the discovery provisions, this time concerning pension scheme unauthorised payments charges...

Costs decision reversed: Metropolitan International Schools Ltd v HMRC [2024] UKFTT 320 (TC) (10 April 2024) is a slightly odd decision where a FTT judge reversed her own decision about an award of costs against HMRC. The details are probably of...