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HMRC POWERS


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.
Steven Porter and Sam Wardleworth (Pinsent Masons) provide a refresher guide to these ‘game changing’ regimes.
Craig Thomson (CSM Tax Consulting) and Jon Preshaw (Jon Preshaw Tax Ltd) examine a recent tribunal decision that provides useful guidance on HMRC information requests and closure notices in the context of DPT enquiries.
Recent trends in the contentious tax world, by Robert Waterson and Constantine Christofi (RPC).
Card image Yvonne Cypher Basim Khattab Don Morley
Don Morley, Yvonne Cypher and Basim Khattab (PwC) explain the importance of businesses retaining documentation of commercial decision making as HMRC increasingly focuses on areas of international tax risk.

HMRC can’t wait forever to make a discovery assessment.

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