HMRC POWERS

Barrister Michael Thomas (Pump Court Tax Chambers) believes there is a disturbing trend in our tax jurisprudence: an increasing number of important decisions made by HMRC are only capable of being challenged on a judicial review basis.

Cristiana Bulbuc

Lee Ellis

Hyrax and Curzon Capital Ltd consider for the first time the provisions governing HMRC’s ability to seek an order that a scheme is notifiable under DOTAS. Lee Ellis and Cristiana Bulbuc (Stewarts Law) consider the practical implications.

Steven Porter

Catherine Robins

Investigations are taking longer, but HMRC’s new facility offers multinationals the prospect of quicker resolution for certain disputes.

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) consider the recent spate of IR35 cases that have been considered by the First-tier Tribunal, HMRC's increasing use of 'jeopardy amendments' and the increasing number of judicial review challenges being brought against HMRC.

Natalie Martin

The judgment in Tooth increases the weight of authority behind the issue of 'staleness', but that concept is not yet settled.

Ian Robotham

Clara Boyd

Although the Court of Appeal decided that HMRC had not made a discovery, the judgment contains unhelpful comments for taxpayers, as Clara Boyd and Ian Robotham (Pinsent Masons) explain.

Sabina Margulies

Sabina Margulies (Lexis®PSL Tax) reviews lessons from the Court of Appeal judgment.

Jenny Tevlin Annis Lampard Morgan Harries

Despite little change in the primary law, HMRC's practice over its information powers is changing due to continued pressure to increase tax yield and demands for data from its international counterparts, as experts at Deloitte explain.

Richard Jeens

Rose Swaffield

The 2019 loan charge teaches us that there is more to statutory time limits than the technical analysis, write Richard Jeens and Rose Swaffield (Slaughter and May).

Ben Jones

Kunal Nathwani

The international tax compliance landscape has become increasingly complicated and often unclear, as Ben Jones and Kunal Nathwani (Eversheds Sutherland) report.

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