COMPLIANCE

Barrister Michael Thomas (Pump Court Tax Chambers) believes there is a disturbing trend in our tax jurisprudence: an increasing number of important decisions made by HMRC are only capable of being challenged on a judicial review basis.

Helen Adams

Recent court decisions suggest that the meaning of 'deliberate' behaviour now differs for ‘discovery’ assessments compared to penalties for errors, writes Helen Adams (BDO).

Cristiana Bulbuc

Lee Ellis

Hyrax and Curzon Capital Ltd consider for the first time the provisions governing HMRC’s ability to seek an order that a scheme is notifiable under DOTAS. Lee Ellis and Cristiana Bulbuc (Stewarts Law) consider the practical implications.

Steven Porter

Catherine Robins

Investigations are taking longer, but HMRC’s new facility offers multinationals the prospect of quicker resolution for certain disputes.

Patrick Cannon

Barrister Patrick Cannon (15 Old Square) provides first hand insight on when and how to use mediation to resolve tax disputes.

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) consider the recent spate of IR35 cases that have been considered by the First-tier Tribunal, HMRC's increasing use of 'jeopardy amendments' and the increasing number of judicial review challenges being brought against HMRC.

Peter Vaines

Is it possible that this unhappy episode could be coming to a conclusion?

Clara Boyd

Ian Robotham

Although the Court of Appeal decided that HMRC had not made a discovery, the judgment contains unhelpful comments for taxpayers, as Clara Boyd and Ian Robotham (Pinsent Masons) explain.