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HMRC powers
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HMRC powers
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
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 9 January 2026
Agreement reached on Pillar Two ‘side-by-side’ package
Late change lifts BPR/APR cap
New guidelines on imported hybrid mismatch rules
VAT treatment of supplies of temporary medical staff
CASES
Read all
HMRC v Hotel La Tour Ltd
County Insurance Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
R Sehgal v HMRC
Other cases that caught our eye: 9 January 2026
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
Finance Bill 2026 published
Tax in 2025: the good, the bad and the ugly
A year at the Tax Bar in 2025
End of year musings on corporate tax
R&D tax in 2025: the calm after the storm?