HMRC-POWERS

They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) comment on the end of the remittance basis, the ‘absolute mess’ that is the double remittance situation and a potentially worrying change in HMRC’s view on the taxation of capital payments in ancillary relief on divorce.

Bryn Reynolds

Bryn Reynolds (Pinsent Masons) examines the recent Jeffries case which illustrates the potential taxpayer pitfalls surrounding protective assessments.

Revocation of pension protection certificate.

David Alcock

Ritchie Tout

David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain why these structures are increasingly under the spotlight.

Rebekka Sandwell

Colin Askew

Rebekka Sandwell and Colin Askew (Eversheds Sutherland) consider the use of ‘conditional contracts’ in order to benefit from pre-Budget CGT rates.

HMRC must reconsider discretion not to apply PAYE obligations.

CA holds that discretionary payments to LLP members were taxable as miscellaneous income.

FTT dismisses taxpayer’s public law arguments against CIS determinations.

Procedure for assessing penalties:I Majid v HMRC [2024] UKFTT 491 (TC) (25 May) is what might be seen as a routine appeal against a penalty determination, but there is one point of general interest. An officer of HMRC had spoken to the...

Dan Williams

Adam Craggs

HMRC have formidable information gathering powers against which there are limited rights of appeal. Adam Craggs and Dan Williams (RPC) look at three common types of information notice and the extent to which they can be challenged.

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