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HMRC-POWERS

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...

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Dan Williams

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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.

The limited circumstances in which HMRC can cancel a VAT registration number.

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...

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Mark Whitehouse

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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.

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Christopher Kientzler

Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.

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Joel Cooper

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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.

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Redrawing the line: modernising the taxation of distributions

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Reckless tax statements: a lower threshold for crime?

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Permanent Establishment exemption: preparing for mandatory application

Alison Lobb , Lisa Shipley

The 2026 loan charge settlement scheme: the beginning of the end?

The 2026 loan charge settlement scheme: the beginning of the end?

David Pett

The Orsted ‘tax nothing’

The Orsted ‘tax nothing’

Andrew Page

Budget 2026: options for taxing wealth

Budget 2026: options for taxing wealth

Dom Rothbarth

HMRC powers and the taxpayer relationship: when is enough, enough?

HMRC powers and the taxpayer relationship: when is enough, enough?

Chris Sanger , Constantine Christofi

Redrawing the line: modernising the taxation of distributions

Redrawing the line: modernising the taxation of distributions

Jill Gatehouse , Emily Szasz

Reckless tax statements: a lower threshold for crime?

Reckless tax statements: a lower threshold for crime?

Adam Craggs , Tom Jenkins

Permanent Establishment exemption: preparing for mandatory application

Permanent Establishment exemption: preparing for mandatory application

Alison Lobb , Lisa Shipley

The 2026 loan charge settlement scheme: the beginning of the end?

The 2026 loan charge settlement scheme: the beginning of the end?

David Pett

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