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HMRC powers
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HMRC POWERS
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.
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
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.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 10 October 2025
Government no closer on wealth tax
ATT launches MTD ‘digital readiness tips’ for agents
R&D claims down but support remains stable
Reactivating clients’ self-assessment accounts
CASES
Read all
GW Martin & Co Ltd and another v HMRC
A Weis v HMRC
Other cases that caught our eye: 10 October 2025
Isle of Wight NHS Trust v HMRC
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
HMRC’s new NIC guidance on internationally mobile employees
The tax Budget cycle
More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
MOST READ
Read all
HMRC’s new NIC guidance on internationally mobile employees
Jumpman Gaming Ltd v HMRC
GfC 13 and the filing position: nothing to see here?
Isle of Wight NHS Trust v HMRC
Legislating against promoters of marketed tax avoidance scheme