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HMRC powers
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HMRC-POWERS
The Oaks (Gatley) Ltd v HMRC
FTT dismisses taxpayer’s public law arguments against CIS determinations.
Another case that caught our eye: 28 June 2024
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...
Dealing with HMRC information notices
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.
Elphysic Ltd and others v HMRC
The limited circumstances in which HMRC can cancel a VAT registration number.
Other cases that caught our eye: 23 February 2024
Follower notices and penalties: R Baker v HMRC [2024] UKFTT 126 (TC) (6 February 2024) is the second case in which the tribunal has allowed appeals against penalties under the follower notice regime arising from the taxpayer participating in a scheme...
Seeing the broader picture: HMRC’s information exchange powers and obligations
Mark Whitehouse
Miranda Edwards
Tax authorities have access to more sources of information than ever before. Mark Whitehouse and Miranda Edwards (PwC) explore recent developments in HMRC’s international and domestic information powers and consider the implications for multinationals.
Fishing and fishy? HMRC third party interviews in employment tax investigations
Christopher Kientzler
Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.
How to handle transfer pricing discovery assessments
Joel Cooper
Paula Ruffell
Joel Cooper and Paula Ruffell (EY) outline the steps to consider if a
‘protective’ discovery assessment is issued for a transfer pricing matter.
Private client review for April 2023
Hannah Kalveks
Edward Reed
SDLT mixed use rates, procedural issues, taxpayer confidentiality and HMRC
‘fishing expeditions’ are among the topics reviewed by Edward Reed and
Hannah Kalveks (Macfarlanes).
Hoey: you’d better PAYE up
Hugh Gunson
Guy Bud
Hugh Gunson and Guy Bud (Charles Russell Speechlys) examine the Court of Appeal’s decision which has potentially far-reaching consequences for the PAYE system.
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Staggered roll-out for mandatory tax adviser registration
Consultation on proposed UK corporate re-domiciliation regime
Cryptoassets taxation: stablecoins
Administrative change to CIR rules
NIC regs mirror tax changes
CASES
Read all
HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
R (oao Rokos) v HMRC
Other cases that caught our eye: 10 April 2026
HMRC v C Brzezicki
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
J Hosking v HMRC
Exceptional circumstances – but which way?
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker