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INVESTIGATIONS


HMRC are adopting a tougher stance with those who continue to deliberately mislead or refuse to cooperate, despite being in the COP 9/CDF process, writes Simon York CBE (Deloitte).
Adam Craggs & Liam McKay (RPC) report a year marked by tighter procedural frameworks, clarifying case law and an intensified HMRC focus on both avoidance and criminal activity.
HMRC’s preferential ranking brings into sharp focus their requirements to evidence and substantiate their claims in an insolvency, as Liesl Fichardt and Emily Au (Quinn Emanuel) explain.
Michael Paulin (1 Crown Office Row) considers the impact of HMRC’s broader view of tax fraud in its updated COP 9.
Jack Prytherch (Osborne Clarke) sets out the practical steps that taxpayers can take to minimise delays in their disputes with HMRC and so mitigate any additional interest charged.
Steven Porter and Penny Simmons (Pinsent Masons) provide guidance for large businesses on managing IR35 compliance risks.
Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.
Clare Reeve Curatola and Kate Ison (Bryan Cave Leighton Paisner) provide practical insight on maximising the protection of legal professional privilege.
Adam Craggs and Michelle Sloane (RPC) explore the powers commonly deployed by HMRC during a criminal investigation.
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).
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