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HMRC powers
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HMRC powers
HMRC POWERS
You’re barred: failure to disclose in the FTT
Sophie Rhind
Victoria Braid
Sophie Rhind and Victoria Braid (Macfarlanes) examine a recent case in which the tribunal takes a tough approach to HMRC’s failure to comply with an unless order.
How to handle R&D enquiries
Carrie Rutland
Helen Adams
Helen Adams and Carrie Rutland (BDO) provide a practical guide.
A tougher approach at HMRC, but at what cost?
Ray McCann
Consultant and former CIOT president Ray McCann discusses the limitations of HMRC’s recent compliance strategy and suggests a more pragmatic approach.
Why we’ve revised COP 9: the view from HMRC
Zoe Gascoyne
Zoe Gascoyne (HMRC) explains the importance of understanding the revised COP 9 and the contractual disclosure facility offer made as part of the process.
Schedule 36: a stitch in time
Keith Gordon
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).
Mitchell: taxpayer confidentiality and a crisis of confidence?
Robert Waterson
Liam McKay
Robert Waterson and Liam McKay (RPC) suggest that the recent
Mitchel
l
case is indicative of a wider sense of apprehension in HMRC.
How is HMRC using financial institution notices?
Jack Prytherch
Jack Prytherch (CMS) discusses the key updates from the first report on HMRC’s use of financial institution notices.
Privileged documents and third party notices: how far do HMRC’s information powers reach?
Oliver Marre
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.
Couldn’t careless? Reasonable care and the role of professional advisers
Constantine Christofi
Adam Craggs
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: a dangerous approach
Craig Kirkham-Wilson
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.
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105
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 25 April 2025
DST was always meant to be temporary, says Exchequer Secretary
HMRC change approach to CIR reporting
R&D relief: HMRC to update guidance on going concern rules and intra-group transfers
Pre-development costs consultation postponed
CASES
Read all
WTGIL Ltd v HMRC
Vaccine Research Limited Partnership and another v HMRC
George Mantides Ltd v HMRC
Refinitiv Ltd and others v HMRC
Other cases that caught our eye: 25 April 2025
IN BRIEF
Read all
A statutory residence test bear-trap
Protected income and offshore income gains
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
MOST READ
Read all
VAT road fuel scale charges updated
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way
FA 2025 review: The new FIG regime: who are the real winners?
Loan Charge review: call for evidence