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HMRC


Measuring Tax Gaps 2023: analysis and predictions starpremium
Card image Craig Kirkham-Wilson
Craig Kirkham-Wilson (Simmons & Simmons) examines Measuring Tax Gaps 2023 and predicts more enforcement activity in relation to large businesses.
14 September 2023
Impact Contracting Solutions Limited v HMRC premium
Can HMRC rely on a principle of EU law to cancel a VAT registration? 
12 September 2023
Scottish Power (SCPL) Ltd and others v HMRC premium
Payments in lieu of penalties are non-deductible.
12 September 2023
HMRC’s evolving approach to tax compliance for the largest businesses starpremium
Card image Nicole Newbury
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. 
7 September 2023
A tax on conscience? A moral dilemma for non-residents premium
Card image Robert Waterson
Card image Liam McKay
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).
7 September 2023
Other cases that caught our eye: 8 September 2023 premium
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)...
5 September 2023
JTIAC reaches the Upper Tribunal: onward, through the Slough of Despond, but for which purpose? premium
Card image Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) is disappointed by a recent Upper Tribunal decision on the unallowable purpose rule.
30 August 2023
Judicial developments in recent treaty cases premium
Card image Constantine Christofi
Card image David Goldberg QC
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).
30 August 2023
HMRC v Part 26A: can you cram the Crown? premium
Card image Abby Martin Lisa Rickelton Alex Lewis
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report. 
26 July 2023
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections? premium
Card image Nuel Oji
Card image Stuart Walsh
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
26 July 2023
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