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INVESTIGATIONS


Following the censure HMRC received over the HSBC ‘Swiss leaks’ before the Public Accounts Committee on 11 February, as well as further press criticism, HMRC issued a statement on when and how it came by the leaked HSBC Suis

Tori Magill (Pinsent Masons) answers a query on a client who participated in a marketed avoidance scheme and has received a COP9 notice

The Swiss arm of British bank HSBC has been accused of helping its wealthy clients with offshore tax avoidance – and even tax evasion – in the national and international press.

A surge in revenue collected by HMRC’s affluent unit shows that the department is no longer focusing solely on the super-rich, according to a Pinsent Masons briefing

Jennie Granger (HMRC) writes about the new approach of HMRC’s enforcement and compliance business.

Geoff Lloyd and Paul Dennis (EY) examine how ADR is working for large businesses

On 16 January 2015, the European Commission published the non-confidential details of its decision taken in October 2014 to open a formal state aid investigation into a ruling by the Luxembourg tax authorities in favour of Amazon’s transfer pricing arrangements dating back to 2003.

Legal professional privilege and search warrants

Despite a general perception to the contrary, it is possible to appeal a follower notice penalty, writes Chris Davidson (KPMG)

As announced at Autumn Statement, HMRC is now consulting until 12 March 2015 on a new power, enabling HMRC to achieve early resolution and closure, including payment, in respect of one or more aspects of a tax enquiry, whilst leaving other aspects of the tax enquiry open.

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