Taxpayers increasingly need to rely on statements made by HMRC which do not have the force of law, such as HMRC clearances given to a taxpayer or HMRC guidance. In this back-to-basics guide, Christopher Harrison and David Stainer (Allen & Overy) provide an overview of the principles which govern a taxpayer’s ability to rely on written statements by HMRC, particularly on legitimate expectation.
Andrew Goldstone and Sarah Albury (Mishcon de Reya) report on recent updates in the private client arena, including: the proposed new strict liability criminal offence; changes to the LDF; the common reporting standard in the UK; strengthening DOTAS and the VADR; and the Presumption of Death Act.
Former HMRC impact assessment programme manager Wendy Bradley raises concerns over the direct recovery of debts (DRD) consultation process.
Go directly to jail; do not pass ‘go’; do not collect £200. Is HMRC’s approach getting out of hand, asks Peter Vaines, partner, Squire Patton Boggs
The City of London Law Society has called for the direct recovery of debt (DRD) proposals to be dropped in response to HMRC’s much-discussed public consultation Direct recovery of debts, which closed on Tuesday.
James Bullock considers how effective the new ‘accelerated payments’ powers granted to HMRC will be in curbing tax avoidance schemes.
Ray McCann argues that HMRC might come to regret accelerated payment notices
HMRC has published a tax information and impact note on the new rules which will allow it to issue conduct notices to promoters of tax avoidance schemes. The note stresses that these rules have effect since Royal Assent of the Finance Bill (i.e. 17 July 2014).