Zoe Gascoyne (HMRC) explains the importance of understanding the revised COP 9 and the contractual disclosure facility offer made as part of the process.
There is nothing wrong with taxpayers insisting on their legal rights when faced with an HMRC information notice, writes barrister Keith Gordon (Temple Tax Chambers).
Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.
Whilst taking professional advice will usually mean a taxpayer has taken reasonable care, not taking advice does not necessarily mean a taxpayer has been careless, write Adam Craggs and Constantine Christofi (RPC).
The APPG on responsible tax proposes criminally prosecuting tax advisers for avoidance planning. Craig Kirkham-Wilson (Simmons & Simmons) explains why the report is based on some misguided assumptions.
Hugh Gunson and Guy Bud (Charles Russell Speechlys) examine the Court of Appeal’s decision which has potentially far-reaching consequences for the PAYE system.
Sarah Bond (Freshfields Bruckhaus Deringer) examines the Upper Tribunal decision that represents what is likely to be the first major instalment in a series of cases on the VAT grouping of offshore service companies.
A growing number of taxpayers can expect to be involved in ‘early stage’ tax disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith) provide a practical guide for their advisers.
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