PENALTIES

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).

Edward Reed

Damiano Sogaro

Edward Reed and Damiano Sogaro (Macfarlanes) report on the latest on information notices, nudge letters, penalties and more.

Penalties for incorrect BADR claim upheld.

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...

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).

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).

Helen Adams

Helen Adams (BDO) offers some thoughts on the options and challenges posed by the potential reforms.

Inaccuracies were careless but not deliberate.

Upper Tribunal clarifies application of the follower notice regime.

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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