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HMRC POWERS


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.
Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision which stresses the need for accountability and transparency from HMRC when issuing determinations.
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).
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.
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.
Adam Craggs and Liam McKay (RPC) examine the current consultation which could help influence HMRC’s future approach to dispute resolution.
Michael Paulin (1 Crown Office Row) considers the impact of HMRC’s broader view of tax fraud in its updated COP 9.
Malcolm Gammie CBE KC (One Essex Court) examines recent Government proposals which, he says, leave little doubt that tax avoidance, like tax evasion, is to be regarded as a criminal activity.
A recent High Court decision provides valuable guidance for taxpayers seeking to challenge enforcement action taken by HMRC’s Debt Management team, write Michelle Sloane and Daniel Williams (RPC).
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