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PENALTIES
Rebel without a causal link: HMRC’s position on proving carelessness
Sophie Rhind
Victoria Braid
Mainpay
should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
Private client review for September 2024
Damiano Sogaro
Edward Reed
Edward Reed and Damiano Sogaro (Macfarlanes) report on the latest on information notices, nudge letters, penalties and more.
P Cox and another v HMRC
Penalties for incorrect BADR claim upheld.
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...
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
Following a recent case, we can probably expect HMRC to be less flexible
on taxpayer requests for more time to comply with information notices,
writes Matthew Greene (Stewarts).
Full proof: more needed from HMRC to discharge their burden of proof
Sophie Rhind
It is encouraging to see the FTT dealing robustly with situations where HMRC
fail to discharge their burden of proof, writes Sophie Rhind (Macfarlanes).
Reforming tax dispute processes: HMRC’s call for evidence
Helen Adams
Helen Adams (BDO) offers some thoughts on the options and challenges posed by the potential reforms.
S Thompson v HMRC
Inaccuracies were careless but not deliberate.
K Pitt v HMRC
Upper Tribunal clarifies application of the follower notice regime.
Other cases that caught our eye: 2 February 2024
Double taxation relief on foreign dividend income: It is now well established that significant elements of the UK’s tax regime governing the treatment of foreign dividends received by UK companies were incompatible with EU principles of freedom...
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EDITOR'S PICK
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
1 /7
Freebies
David Whiscombe
2 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
3 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
4 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
5 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
6 /7
SDLT: gardens, grounds and grazing
Max Schofield
7 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
NEWS
Read all
HMRC manual changes: 18 October 2024
HMRC update ERS guidance for Vermilion
Employment Rights Bill published
Claims and conditions for enhanced rate of AVEC
ISAs and fractional shares
CASES
Read all
Panayi v HMRC
BTR Core Fund JPUT v HMRC
Other cases that caught our eye: 18 October 2024
HMRC v P Gould
Putney Power Ltd and another v HMRC
IN BRIEF
Read all
Bed and breakfasting before the Budget?
NICs and the Budget
Non-dom reforms: shaping the regime
Non-dom reforms: IHT aspects
EU Watch: new mandate, new tax priorities
MOST READ
Read all
One minute with... Dave Chaplin
Budget Responsibility Act brought into force
Case watch
Avoiding avoidance
Direct payment scheme for IHT extended to investment providers