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HMRC powers
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HMRC POWERS
Budget 2025: Expect a more proactive HMRC and a tougher compliance environment
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...
Legislating against promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) examines the draft legislation proposing Universal Stop Regulations and Promoter Action Notices, raising concerns over their breadth and lack of safeguards.
Secondary legislation: the importance of statutory instruments
Alan Evans CB
Alan Evans CB, HMRC’s General Counsel and Director General of the
department’s Legal Group, discusses an often overlooked but crucial part to
the running of the tax system.
Legislation day 2025: Requirement for advisers to register with HMRC
David Whiscombe
Worse than useless?
BGC Services: lacking determination
Matthew Greene
Guy Bud
Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision
which stresses the need for accountability and transparency from HMRC
when issuing determinations.
Rettig: HMRC’s tactical approach to public law challenges
Richard Doran
John Hayton
Principled positions often adopted by HMRC can have the practical effect of
avoiding or otherwise delaying judicial scrutiny of their decision-making process,
write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).
Keeping the receipts: HMRC’s burden in company insolvencies
Liesl Fichardt
Emily Au
HMRC’s preferential ranking brings into sharp focus their requirements to
evidence and substantiate their claims in an insolvency, as Liesl Fichardt and
Emily Au (Quinn Emanuel) explain.
Future focus: the potential reform of behavioural penalties
Thomas Wilkinson
Kate Garcia
Kate Garcia and Thomas Wilkinson (Shoosmiths) review the consultation on
the potential redesign or reform of penalties imposed for inaccuracies in tax
returns and failures to notify.
Improving HMRC’s approach to dispute resolution
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) examine the current consultation
which could help influence HMRC’s future approach to dispute resolution.
Code of Practice 9 and discovery assessments
Michael Paulin
Michael Paulin (1 Crown Office Row) considers the impact of HMRC’s
broader view of tax fraud in its updated COP 9.
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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 November
HMRC manual changes: 5 December 2025
Further practitioner reaction to Budget tax measures
Finance Bill
HMRC publish OOTLAR and tax tables, eventually
CASES
Read all
Places for People Homes Ltd v HMRC
Executor of P Goudman-Peachey v HMRC
HMRC v M Breen
Other cases that caught our eye: 5 December 2025
AD Bly Groundworks and Civil Engineering Ltd v HMRC
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
Budget 2025: HMRC’s whistleblower scheme launches with limited detail
Tax Journal's 2025 Budget coverage
Budget 2025 changes to the share exchanges and reorganisation rules
The 2025 loan charge review and Government response: the final chapter?
Budget 2025: DST heading for a Clash: should I stay, or should I go now?