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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
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
Read all
TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime