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Craig Kirkham-Wilson (Simmons & Simmons) examines Measuring Tax Gaps 2023 and predicts more enforcement activity in relation to large businesses.
Can HMRC rely on a principle of EU law to cancel a VAT registration? 
Payments in lieu of penalties are non-deductible.
HMRC’s large business director, Nicole Newbury, outlines the department’s  approach, including priority areas of focus and how it is evolving to reflect wider changes in the economy and customers’ circumstances. 
The Upper Tribunal has, for the first time, considered the meaning of ‘exceptional circumstances’ in the context of statutory residence – and it has set the bar extremely high, write Robert Waterson and Liam McKay (RPC).
Calculating CJRS payments: We have seen a number of cases recently concerning the furlough (CJRS) scheme. Most of these have been about whether an employee meets the eligibility requirements. Ark Angel Ltd v HMRC [2023] UKFTT 705 (TC) (4 August 2023)...
Gerald Montagu (Gide Loyrette Nouel) is disappointed by a recent Upper Tribunal decision on the unallowable purpose rule.
Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).
Card image Lisa Rickelton, Alex Lewis, Abby Martin
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report. 
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.