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HMRC powers
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HMRC powers
HMRC POWERS
HMRC powers and the taxpayer relationship: when is enough, enough?
Constantine Christofi
Craig Kirkham-Wilson
Chris Sanger
New HMRC measures risk cumulative constitutional and practical
effects that piecemeal consultation may fail to reveal, write Chris Sanger,
Constantine Christofi and Craig Kirkham-Wilson (EY).
HMRC’s Litigation and Settlement Strategy: overdue for reform
Waqar Shah
HMRC have indicated that they intend to update their litigation and settlement policy later this year. Waqar Shah (Kingsley Napley) considers why the policy is ripe for change.
Company tax return standardisation: clarity or challenge?
Andrew Hawley
Andrew Hawley (Crowe UK) weighs the trade-off in HMRC’s CT return
reforms: fewer routine ‘what does this mean?’ enquiries on the one hand,
more targeted scrutiny of complex and subjective positions on the other.
MTD regulations: legislation at the eleventh hour
Emma Rawson OBE
Emma Rawson (ATT) reviews the MTD for Income Tax regulations,
highlighting late legislative changes, complex entry and exit rules, quarterly
reporting mechanics, and the wide-ranging exemption regime.
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Nick Thornton (Fried Frank) explains why clearing the entry conditions of the QAHC regime is only the start, and how accounting treatment, CIR and funding design can derail intended outcomes.
HMRC’s Customer Compliance Group explained
Amit Puri
Amit Puri (Pure Tax Investigations) outlines the structure, resourcing and recent performance of HMRC’s Customer Compliance Group, including trends in compliance yield and investigation activity.
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hartley Foster (Addington Chambers) examines the right to obtain information from public authorities such as HMRC, via the Freedom of Information Act 2000, and the restrictions on that right.
Tax in 2025: the good, the bad and the ugly
Heather Self
Heather Self (Blick Rothenberg) praises greater HMRC transparency while
warning of deepening fiscal drag and policy inconsistency.
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.
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EDITOR'S PICK
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
1 /7
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
,
Martin Verrall
2 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
3 /7
The Orsted ‘tax nothing’
Andrew Page
4 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
5 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
6 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
7 /7
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
NEWS
Read all
Founders’ Relief: tax bodies warn over eligibility and technical traps
LISA withdrawal charge reduced
HMRC confirm VAT treatment of public EV charging
Donated medicines to be zero-rated
New HMRC withholding tax guidance
CASES
Read all
N Powell v HMRC
Inngrays Ltd v HMRC
Portsmouth City Council v HMRC
Other cases that caught our eye: 6 November 2026
Abbey Group Ltd v HMRC
IN BRIEF
Read all
Distributions reform: unresolved questions
CGT: irrecoverable loans
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
MOST READ
Read all
Budget 2026: Sovereign immunity - a more considered reform
Budget 2026: the tax measures
Tax Journal's 2026 Budget coverage
Case watch
Budget 2026: Driving good growth in every tax code