PENALTY

Sandy Bhogal

In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) agreed a Two-Pillar Solution to address the tax challenges arising from the digitalisation of the economy. Pillar One of the Two-Pillar Solution contains two...

Adam Craggs

Tom Jenkins

Adam Craggs and Tom Jenkins (RPC) examine the proposed criminal offence of making reckless untrue statements to HMRC and the concerns surrounding its scope and safeguards.

Adam Craggs

Another procedural layer bolted onto an already intricate system.

Jake Landman

Abigail McGregor

Jake Landman and Abigail McGregor (Pinsent Masons) revisit the discretionary regime allowing HMRC to suspend penalties for careless inaccuracies, in light of recent Upper Tribunal guidance.

Jan Kolasa Ben Webster Tom O’Reilly

Ben Webster, Tom O’Reilly and Jan Kolasa (Fieldfisher) assess the strengths and weaknesses of the Digital Disclosure Service.

Sophie Rhind

Elvira Colomer Fatjo

Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review some notable rulings on a range of procedural issues, as well as recent changes to the tribunal rules.

Regulatory redress payments akin to penalties not deductible, rules Supreme Court

As 2026 passes its halfway point, we take stock of a busy year in the courts. From decisions on partnership tax and treaty abuse to VAT, inheritance tax planning to employment status, here is our pick of ten key cases shaping tax practice this year....

SKAT fraud claim survives issue estoppel challenge: Readers may recall SKAT’s attempt to pursue a fresh fraud claim in England against MCML, formerly ED&F Man Capital Markets Ltd, over allegedly false tax vouchers used to obtain Danish...

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