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Home
Sch 36
Home
Sch 36
SCH-36
AAA Oriental Ltd v HMRC
Sch 36 information notice upheld.
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).
Seeing the broader picture: HMRC’s information exchange powers and obligations
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.
Fishing and fishy? HMRC third party interviews in employment tax investigations
Christopher Kientzler
Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.
Schedule 36: a stitch in time
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).
Private client review for June 2023
Edward Reed
Andrew Crozier
Recent cases on information notices, penalties, and what is and is not a ‘mistake’ are reviewed by Edward Reed and Andrew Crozier (Macfarlanes).
Sch 23 bulk data-gathering powers: policing the gig economy
Matthew Greene
Ian Hyde
Ian Hyde and Matthew Greene (Osborne Clarke) discuss HMRC’s data-gathering powers that provide an effective tool to police the gig economy.
HMRC’s investigatory powers outside the normal enquiry limits
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).
Developments in HMRC’s formal information powers
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.
Extending HMRC’s civil information powers
Helen Adams
Dawn Register
HMRC is consulting on amending its civil information powers. Dawn Register and Helen Adams (BDO) examine what’s proposed.
EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
Tax Journal authors for January
HMRC manual changes: 30 January 2026
Tax bodies back Lords concerns over IHT reforms, including ‘huge’ burden on PRs
Finance Bill 2026 amendments
PAYE changes for employment expenses and gift aid relief
CASES
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
Nimbus: The Disability Consultancy Service Ltd v HMRC
Delphi Derivatives Ltd (in liquidation) v HMRC
Other cases that caught our eye: 30 January 2026
HMRC v MedPro Healthcare
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
COP 9 and serious tax fraud: HMRC’s tougher approach
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
Home offices and hard rocks: the 2025 Update to the OECD’s Model Tax Convention
A Budget for its times? The Scottish Budget 2026/27
Transfer Pricing Guidelines for Compliance