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HMRC POWERS


Retrospective law change on automated processes
Card image Steven Porter
Card image Catherine Robins
The government intends to change the law retrospectively to make it clear that HMRC can use automated processes to issue notices to file returns and to issue penalties, report Catherine Robins and Steven Porter (Pinsent Masons).
26 November 2019
Aozora and legitimate expectation: a guide to nowhere? premium
Card image Constantine Christofi
Card image Robert Waterson
The Court of Appeal's recent decision appears to set a high bar for establishing an unlawful breach of a taxpayer’s legitimate expectation, write Robert Waterson and Constantine Christofi (RPC).
5 November 2019
HMRC enquiries and data interrogation premium
Card image Tony Monger
In every enquiry into a business, HMRC will seek to subject the accounting records to data interrogation. Tony Monger (Mazars) explains what HMRC is looking for.
28 October 2019
Sch 23 bulk data-gathering powers: policing the gig economy premium
Card image Matthew Greene
Card image Ian Hyde
Ian Hyde and Matthew Greene (Osborne Clarke) discuss HMRC’s data-gathering powers that provide an effective tool to police the gig economy.
8 October 2019
Comment: Why the loan charge is unfair
Card image Keith Gordon
The loan charge has driven a coach and horses through the statutory safeguards, writes barrister Keith Gordon (Temple Tax Chambers). 
23 September 2019
HMRC’s investigatory powers outside the normal enquiry limits premium
Card image Helen Adams
Recent decisions reinforce that HMRC is empowered to request information and investigate taxpayers’ positions without using statutory enquiry or information powers, writes Helen Adams (BDO).
17 September 2019
Loan charge review: what now?

Despite the review being an important event, it appears to be very much business as usual at HMRC.

12 September 2019
Contentious tax: quarterly review premium
Card image Adam Craggs
Card image Michelle Sloane

In this quarterly review, Adam Craggs and Michelle Sloane (RPC) consider HMRC’s increasing propensity to seek the production of documents from accountants and other professional advisers, HMRC’s new policy of challenging taxpayers’ loan relationships, and the increase in the number of domicile enquiries launched by HMRC. 

4 September 2019
Comment: In defence of the ‘outstanding loan’ charge premium
Card image David Pett
David Pett (Temple Tax Chambers) argues that outstanding loan charges should be pursued both as a matter of law and social policy.
3 September 2019
Closing HMRC enquiries
Card image Craig Thomson
We now have two recent opposing tribunal judgments on how the partial closure notice rules operate, writes Craig Thomson (Grant Thornton).
22 July 2019
EDITOR'S PICKstar
NEWSRSS Read all
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C Candy v HMRC
30 April 2025
G Quillan v HMRC
30 April 2025
WTGIL Ltd v HMRC
23 April 2025
IN BRIEFRSS Read all
MOST READ Read all
WTGIL Ltd v HMRC
23 April 2025
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