COMPLIANCE

Thomas Peet

Rob Sharpe

Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals to require close companies to report all transactions with participators, assessing the likely compliance burden and unintended impact beyond small businesses, particularly for private capital structures.

Jennifer Plummer

Jennifer Plummer (BDO) considers the requirements for this valuable relief and outlines some of the complexities involved where corporate structures are not straightforward.

Adam Craggs

Liam McKay

Adam Craggs & Liam McKay (RPC) report a year marked by tighter procedural frameworks, clarifying case law and an intensified HMRC focus on both avoidance and criminal activity.

Adam Craggs

The mood music surrounding Budget 2025 was notably downbeat over the past few weeks, with many practitioners expressing pessimism about the scope and direction of the expected changes. Given the strained state of the public finances and the...

Lauren Redhead

Ravi Ahlawat

Lauren Redhead and Ravi Ahlawat (DLA Piper) consider what to do when HMRC enquire into deal funding, and provide a practical playbook from first request to resolution.

Constantine Christofi

Anna Lucey

HMRC’s nudge campaign signals a broader challenge to deductibility under CTA 2009 s 1219, write Anna Lucey and Constantine Christofi (EY).

William H. Morris

As public CbCR regimes expand, AI tools could be used to reveal patterns in global tax data, writes Will Morris (PwC).

Nicholas Gardner

Ruby Hamid

The new fraud offence is a notable expansion of the failure to prevent (FTP) model creating corporate criminal liability. Ruby Hamid and Nicholas Gardner (Ashurst) examine actions for companies, and compare the rules with the existing FTP offences for bribery and tax evasion.

Angela Savin

Andrew James

Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.

Jack Prytherch

Yousuf Chughtai

HMRC’s newly published materials raise important questions about how taxpayers are engaging with the UTT regime in practice, writes Yousuf Chughtai and Jack Prytherch (Osborne Clarke).

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