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HMRC-ENQUIRIES
Suboptimal access: HMRC and data requests
Lucy Collins
Robert Waterson
Robert Waterson and Lucy Collins (Eversheds Sutherland) examine a recent
High Court ruling that could encourage individuals to challenge HMRC if
they feel their personal data rights are being infringed.
Ask an expert: Image rights, offshore structures and UK tax exposure
Sarah Richards
Sarah Richards (Sedulo Tax Advisory) explains why establishing a UAE image rights structure does not in itself remove UK tax exposure.
Eurocent (Buckingham) Ltd v HMRC
HMRC not entitled to deny input tax.
IR35: spotting and responding to an HMRC enquiry
Steven Porter
Penny Simmons
Steven Porter and Penny Simmons (Pinsent Masons) provide guidance for
large businesses on managing IR35 compliance risks.
Full proof: more needed from HMRC to discharge their burden of proof
Sophie Rhind
It is encouraging to see the FTT dealing robustly with situations where HMRC
fail to discharge their burden of proof, writes Sophie Rhind (Macfarlanes).
Private client review for March 2024
Edward Reed
Emma Critchley
Edward Reed and Emma Critchley (Macfarlanes) recap the key private clients announcements in the Spring Budget, and they report some interesting procedural points when challenging HMRC enquiries.
Newcastle United Football Company Ltd v HMRC
HMRC’s retention and internal sharing of copy documents obtained during criminal investigation.
Parker Hannifin (GB) Ltd v HMRC
Information notice requiring email searches was valid
but disclosure request held to be too broad.
Exclusive Promotions Ltd v HMRC
Upper Tribunal dismisses challenges to accelerated payment notices.
Other cases that caught our eye 10 November 2023
Goodwill: M Smith and another v HMRC [2023] UKFTT 912 (TC) (30 October 2023) is an interesting case on the nature of goodwill. Two individual IFAs operated via a company. The business of the company was transferred to an LLP and the capital accounts...
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EDITOR'S PICK
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
1 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
2 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
3 /7
Estoppel and abuse of process in VAT
Claire Logan
4 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
5 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
6 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
7 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
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
NEWS
Read all
UK closes the door on foreign branch loss relief
VAT capital goods scheme changes
New guidance on UK-India social security agreement
Mandatory registration brought into force, eventually
HMRC annual report: compliance yield tops £50bn
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
M Lambourne and another v HMRC
HMRC v Align Technology Switzerland GmbH and another
Other cases that caught our eye: 17 July 2026
HMRC v BlueCrest Capital Management (UK) LLP
IN BRIEF
Read all
Directors’ liability: tax schemes
BlueCrest: the impact for asset managers
When Ramsay does not rescue HMRC
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
MOST READ
Read all
Consultation tracker
When Ramsay does not rescue HMRC
Tax and the City for July 2026
BlueCrest: the impact for asset managers
HMRC v BlueCrest Capital Management (UK) LLP