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HMRC powers
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HMRC powers
HMRC-POWERS
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
Georgia Rawlinson
Edward Reed
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
Laura Harper BDO
Jason Land
Jason Land and Laura Harper (BDO) examine HMRC’s updated guidance on
SAO qualifying businesses.
Embiricos and the future of partial closure notices
Catrin Harrison
Hugh Gunson
Dominic Lawrance
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.
Self's assessment: will the UK become a tax haven after Brexit?
Heather Self
It seems unlikely, writes Heather Self (Blick Rothenberg).
No safe havens 2019: HMRC’s renewed focus on offshore non-compliance
Jessica Hocking
Kate Ison
Kate Ison and Jessica Hocking (Bryan Cave Leighton Paisner) examine the key findings and implications from two policy papers published at the time of the Spring Statement.
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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