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Fraud
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Fraud
FRAUD
HMRC’s Customer Compliance Group explained
Amit Puri
Amit Puri (Pure Tax Investigations) outlines the structure, resourcing and recent performance of HMRC’s Customer Compliance Group, including trends in compliance yield and investigation activity.
From check-in to checkmate: Hotelbeds clarifies HMRC’s discretion to allow input tax recovery
Robert Waterson
Ed Griffiths
Rebekka Sandwell
The ruling in
Hotelbeds
underscores the public law duty on HMRC to exercise
their functions fairly, rationally and reasonably, write Robert Waterson and
Ed Griffiths (Eversheds Sutherland).
Fraud: the next ‘failure to prevent’ frontier
Nicholas Gardner
Ruby Hamid
The new fraud offence is a notable expansion of the failure to prevent (FTP)
model creating corporate criminal liability. Ruby Hamid and Nicholas
Gardner (Ashurst) examine actions for companies, and compare the rules
with the existing FTP offences for bribery and tax evasion.
Code of Practice 9 and discovery assessments
Michael Paulin
Michael Paulin (1 Crown Office Row) considers the impact of HMRC’s
broader view of tax fraud in its updated COP 9.
International review for March 2024
Tim Sarson
Tim Sarson (KPMG) reviews the Biden Administration’s FY 2025 tax proposals and the OECD’s new guidance on Amount B of Pillar One.
A look into HMRC’s toolbox during a criminal investigation
Adam Craggs
Michelle Sloane
Adam Craggs and Michelle Sloane (RPC) explore the powers commonly deployed by HMRC during a criminal investigation.
Why we’ve revised COP 9: the view from HMRC
Zoe Gascoyne
Zoe Gascoyne (HMRC) explains the importance of understanding the revised COP 9 and the contractual disclosure facility offer made as part of the process.
The new failure to prevent fraud offence: cheating the public revenue
Dominic Stuttaford
Dominic Stuttaford (Norton Rose Fulbright) considers the scope of a new ‘failure to prevent’ offence and how it differs from the existing corporate criminal offences.
HMRC’s response to the rise of the enabler
Simon York CBE
Simon York (HMRC) explain how HMRC’s Fraud Investigation Service is leading the domestic and international response to tax evasion.
Key issues for in-house tax teams: a checklist
Mark Ellis
James Egert
Chris Holmes
Chris Holmes, Mark Ellis and James Egert (BDO) set out important current corporate and employer tax issues which in-house tax teams should now be addressing.
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EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’