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Penalties
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PENALTIES
Penalty appeals: shedding light on abuse of process
Anastasia Nourescu
HMRC appears to view many penalty appeals as a ‘second bite of the cherry’, even where the tribunal has not considered the earlier decision, writes Anastasia Nourescu (Stewarts).
Tax penalties and human rights: where are we now?
Anastasia Nourescu
Anastasia Nourescu (Stewarts) reviews the main protections offered by the European Convention on Human Rights and considers how they apply to tax penalties.
Private client review for September 2022
Edward Reed
Clare Wilson
Proposed changes to the CGT rules on transfers of property between separating spouses and a tribunal decision on information notices are among the developments reviewed by Edward Reed and Clare Wilson (Macfarlanes).
Uncertain tax treatment: highlights from HMRC’s final guidance
Nick Evans
Kate Alexander
Kate Alexander and Nick Evans (Baker McKenzie) review the newly published
Uncertain Tax Treatments by Large Businesses Manual.
VAT on compensation payments: clarity at last?
Richard Woolich
Katie Raine
Although some uncertainty remains, from 1 April there will be fewer situations where HMRC accepts that early termination and compensation payments are not subject to VAT, write Katie Raine and Richard Woolich (DLA Piper).
Contentious tax quarterly: Winter 2021
Constantine Christofi
Adam Craggs
Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
Private client review for November 2021
Edward Reed
Georgia Rawlinson
Edward Reed and Georgia Rawlinson (Macfarlanes) provide this month’s review of developments affecting private clients.
Private client review for October 2021
Edward Reed
Lisa de Silva
Useful insights on discovery, potentially insolvent estates, the location of cryptoassets for tax purposes and HMRC’s use of nudge letters by Edward Reed and Lisa de Silva (Macfarlanes).
Jersey’s economic substance for partnerships rules
Rupert Lee
New legislation brings certain partnerships within the scope of Jersey’s economic substance regime. Rupert Lee (Deloitte Jersey) reports.
HMRC’s updated SAO guidance: a focus on the main duty
Jason Land
Laura Harper BDO
Jason Land and Laura Harper (BDO) examine HMRC’s updated guidance on
SAO qualifying businesses.
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EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
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
NEWS
Read all
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC phase in mandatory payrolling of benefits from April 2027
ATED pre-return banding checks
Coding out winter fuel payment charge
Pensions advisers urge rethink on IHT
CASES
Read all
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
HMRC v GCH Corporation Ltd and others
Barclays Services Corporation and another v HMRC
Other cases that caught our eye: 19 June 2026
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Consultation tracker
Lifeplus Europe Ltd v HMRC
Sintra, Hall and the reshaping of HMRC’s burden of proof
Management rollovers and share-for-share exchange relief
The UK’s tax certainty problem