Confiscation orders and discovery assessments
When is an application to reduce penalties because of ‘special circumstances’ a better bet than ‘reasonable excuse’? Peter Vaines (Squire Patton Boggs) considers a recent tribunal decision.
Retrospective legislation was lawful
Expert insight on one of the most powerful weapons in HMRC's arsenal
Reliance on accountant and reasonable excuse
Jurisdiction of the UT to hear appeals against information notices
HMRC is right to assert that the ‘no possibilities’ test should be applied immediately after the base loss period for losses from 1 April 2006, but wrong to apply it to periods before that date, writes Peter Cussons (PwC).
FTT’s jurisdiction on legitimate expectation
Reasonable excuse: IT issues
Timothy Jarvis (Squire Patton Boggs) reviews lessons from the Upper Tribunal’s decision in Lobler on rectification and mistake