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HMRC POWERS


It seems the definition of what is an establishment is being gradually extended for political purposes, writes Eloise Walker (Pinsent Masons).

Jason Collins and Stuart Walsh (Pinsent Masons) review a recent tribunal case which highlights the practical difficulties of asserting legal privilege where the taxpayer has to explain their motivations behind a transaction.
 
HMRC is revisiting the way it risk assesses businesses. Lucy Sauvage and Laura Harper (BDO) consider practical issues for those affected.
 

Current taxpayer safeguards for HMRC’s notice powers are neither independent nor accessible, writes Tracey Bowler (Institute for Fiscal Studies).

Adam Craggs and Constantine Christofi (RPC) review a recent tribunal decision which considers disclosure and the practical effect of Sanderson.
 
The decision in Bilta has clarified the scope of privilege in internal investigations undertaken in the context of HMRC enquiries, write Kate Ison and Clare Reeve (Berwin Leighton Paisner).
 
HMRC needs to exercise more care when applying for search and seizure warrants, writes Patrick Cannon (15 Old Square Tax Chambers).
 
Adam Craggs and Constantine Christofi (RPC) examine the judgment and consider where this leaves us.
 

Gary Richards (Mishcon de Reya) asks whether it is now time for a radically different approach to compliance failings.

Sam Mitha CBE interviews HMRC’s executive chairman, Edward Troup, on some of the key issues facing the department.
 
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