INFORMATION-POWERS

Legal advice privilege (LAP) remains a vital right for taxpayers, but its boundaries are far from settled. Jason Collins and Lauren Redhead (DLA Piper) examine LAP in a tax context, including the recent decision in Aabar v Glencore which extends privilege to intra-client group communications.

Miranda Edwards

Mark Whitehouse

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.

Keith Gordon

There is nothing wrong with taxpayers insisting on their legal rights when faced with an HMRC information notice, writes barrister Keith Gordon (Temple Tax Chambers).

Damiano Sogaro

Gideon Sanitt

Damiano Sogaro and Gideon Sanitt (Macfarlanes) review recent litigation on the tribunal's role in determining domicile issues when considering challenges to an enquiry or to information notices.

Gary Barnett

Monique van Herksen

Monique van Herksen and Gary Barnett (Simmons & Simmons) examine a recent decision of the CJEU that presents a setback for taxpayers in this developing area of law.

Kate Ison

Jessica Hocking

A recent Court of Appeal decision reaffirms HMRC’s right to conduct enquiries on an ‘informal’ premise even where there is no statutory basis, write Kate Ison and Jessica Hocking (Bryan Cave Leighton Paisner).

Helen Adams

Helen Adams (BDO) considers the extent to which taxpayers may have a reasonable excuse if they are affected by the coronavirus pandemic and the UK’s lockdown.

Helen Adams

Recent decisions reinforce that HMRC is empowered to request information and investigate taxpayers’ positions without using statutory enquiry or information powers, writes Helen Adams (BDO).

Morgan Harries Annis Lampard Jenny Tevlin

Despite little change in the primary law, HMRC's practice over its information powers is changing due to continued pressure to increase tax yield and demands for data from its international counterparts, as experts at Deloitte explain.