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INVESTIGATIONS
Keeping the receipts: HMRC’s burden in company insolvencies
Liesl Fichardt
Emily Au
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.
Code of Practice 9 and discovery assessments
Michael Paulin
Michael Paulin (1 Crown Office Row) considers the impact of HMRC’s
broader view of tax fraud in its updated COP 9.
Time is money: how to mitigate late payment interest in tax disputes
Jack Prytherch
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.
IR35: spotting and responding to an HMRC enquiry
Penny Simmons
Steven Porter
Steven Porter and Penny Simmons (Pinsent Masons) provide guidance for
large businesses on managing IR35 compliance risks.
Fishing and fishy? HMRC third party interviews in employment tax investigations
Christopher Kientzler
Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.
Privilege considerations in tax investigations
Clare Reeve Curatola
Kate Ison
Clare Reeve Curatola and Kate Ison (Bryan Cave Leighton Paisner) provide practical insight on maximising the protection of legal professional privilege.
A look into HMRC’s toolbox during a criminal investigation
Adam Craggs
Michelle Sloane
Adam Craggs and Michelle Sloane (RPC) explore the powers commonly deployed by HMRC during a criminal investigation.
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).
Early stage tax disputes: a practical guide
Sophie Lloyd
Rob Smith
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.
A welcome return to traditional tax investigations
Andrew Park
Andrew Park (Andersen in the UK) explains that HMRC must be properly resourced to embark on traditional tax investigations to increase funds for public spending.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC to restart direct recovery of tax debts
Tax agents legislation misses the target, says ICAEW
HMRC issue guidance on international employee earnings
Reserved investor funds: new technical note
Umbrella companies: new HMRC PAYE guidance
CASES
Read all
T Pawar v HMRC
MBP Europe Ltd v HMRC
Circleplane Ltd v HMRC
Other cases that caught our eye: 26 September 2025
The Prudential Assurance Company Ltd v HMRC
IN BRIEF
Read all
More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
MOST READ
Read all
Tribunal orders HMRC to disclose whether it used AI in R&D claims
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
EV charging added to advisory fuel rates
Budget 2025 set for 26 November
UK-Vietnam tax treaty updated