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Measuring Tax Gaps 2023: analysis and predictions
Craig Kirkham-Wilson
Craig Kirkham-Wilson (Simmons & Simmons) examines
Measuring Tax Gaps 2023
and predicts more enforcement activity in relation to large businesses.
Impact Contracting Solutions Limited v HMRC
Can HMRC rely on a principle of EU law to cancel a VAT registration?
Scottish Power (SCPL) Ltd and others v HMRC
Payments in lieu of penalties are non-deductible.
HMRC’s evolving approach to tax compliance for the largest businesses
Nicole Newbury
HMRC’s large business director, Nicole Newbury, outlines the department’s approach, including priority areas of focus and how it is evolving to reflect wider changes in the economy and customers’ circumstances.
A tax on conscience? A moral dilemma for non-residents
Liam McKay
Robert Waterson
The Upper Tribunal has, for the first time, considered the meaning of ‘exceptional circumstances’ in the context of statutory residence – and it has set the bar extremely high, write Robert Waterson and Liam McKay (RPC).
Other cases that caught our eye: 8 September 2023
Calculating CJRS payments: We have seen a number of cases recently concerning the furlough (CJRS) scheme. Most of these have been about whether an employee meets the eligibility requirements. Ark Angel Ltd v HMRC [2023] UKFTT 705 (TC) (4 August 2023)...
JTIAC reaches the Upper Tribunal: onward, through the Slough of Despond, but for which purpose?
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) is disappointed by a recent Upper Tribunal decision on the unallowable purpose rule.
Judicial developments in recent treaty cases
David Goldberg QC
Constantine Christofi
Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).
HMRC v Part 26A: can you cram the Crown?
Alex Lewis
Abby Martin
Lisa Rickelton
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Nuel Oji
Stuart Walsh
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
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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