HMRC-POWERS

Adam Craggs

Predictions that Budget 2026 would be a relatively pedestrian affair proved accurate, with a focus on easing cost of living pressures and few surprises. Labour’s manifesto commitment not to raise headline taxes, coupled with an increasingly...

Thomas Peet

Rob Sharpe

Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals to require close companies to report all transactions with participators, assessing the likely compliance burden and unintended impact beyond small businesses, particularly for private capital structures.

Sophie Dworetzsky

In this month’s review, Sophie Dworetzsky (Charles Russell Speechlys) examines a case on distributions from an offshore company, a potentially farreaching proposed change to the definition of permanent establishment and the latest HMRC guidance.

Dominic Lawrance

Sophie Dworetzsky

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.

HMRC granted permission to amend their statement of case

HMRC’s powers: Soft Drinks Levy

HMRC’s power to deregister where VAT fraud

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.