HMRC POWERS

Helen Adams

Recent decisions reinforce that HMRC is empowered to request information and investigate taxpayers’ positions without using statutory enquiry or information powers, writes Helen Adams (BDO).

Despite the review being an important event, it appears to be very much business as usual at HMRC.

Michelle Sloane

Adam Craggs

In this quarterly review, Adam Craggs and Michelle Sloane (RPC) consider HMRC’s increasing propensity to seek the production of documents from accountants and other professional advisers, HMRC’s new policy of challenging taxpayers’ loan relationships, and the increase in the number of domicile enquiries launched by HMRC.

David Pett

David Pett (Temple Tax Chambers) argues that outstanding loan charges should be pursued both as a matter of law and social policy.

Craig Thomson

We now have two recent opposing tribunal judgments on how the partial closure notice rules operate, writes Craig Thomson (Grant Thornton).

Michael Thomas KC

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.

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.

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.