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HMRC powers
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HMRC powers
HMRC-POWERS
Private client review for April 2023
Edward Reed
Hannah Kalveks
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.
20 questions: HMRC’s civil and criminal powers
Constantine Christofi
Adam Craggs
A detailed guide by Adam Craggs and Constantine Christofi (RPC).
Private client review for November 2021
Edward Reed
Georgia Rawlinson
Edward Reed and Georgia Rawlinson (Macfarlanes) provide this month’s review of developments affecting private clients.
HMRC’s updated SAO guidance: a focus on the main duty
Jason Land
Laura Harper BDO
Jason Land and Laura Harper (BDO) examine HMRC’s updated guidance on
SAO qualifying businesses.
Embiricos and the future of partial closure notices
Dominic Lawrance
Hugh Gunson
Catrin Harrison
Catrin Harrison, Dominic Lawrance and Hugh Gunson (Charles Russell Speechlys)
examine an Upper Tribunal decision that is disappointing for taxpayers and
removes a strategic weapon for anyone faced with a domicile enquiry.
Litigation privilege and structuring advice
Dominic Stuttaford
Tax structuring advice received and implemented, even where there is a
perceived risk of challenge, will not benefit from litigation privilege, writes
Dominic Stuttaford (Norton Rose Fulbright).
Notifying HMRC of uncertain tax treatments: transparency or confusion?
Matthew Greene
Ian Hyde
Ian Hyde and Matthew Greene (Osborne Clarke) examine the government’s plans to require large businesses to notify HMRC of uncertain tax treatments they have adopted after April 2021.
Contentious tax: quarterly review
Constantine Christofi
Adam Craggs
Adam Craggs and Constantine Christofi (RPC) review recent developments over the course of the past three months.
HMRC powers: the new professional standards committee
Paul Aplin OBE
Paul Aplin OBE (A C Mole & Sons) welcomes proposals for a new professional standards committee.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
Read all
TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime