Jayne Newton highlights practical concerns for clients
Aileen Barry believes that Charlton will be a landmark case on discovery assessments, providing guidance on what constitutes ‘discovery’, ‘information made available’ and ‘reasonably inferred’.
HMRC has offered a settlement opportunity for participants in certain tax avoidance schemes. Jonathan Levy examines the detail, and suggests there is a tension between this settlement opportunity and HMRC's overarching litigation and settements strategy.
James Hume and Steve Edge examine the issues to consider before engaging in substantive discussions with HMRC on the settlement opportunity for employee benefit trusts.
R (on the application of Prudential plc and another) v Special Commissioner of Income Tax and another
HMRC guidance
HMRC stresses that ‘tax under consideration’ is not the same as tax owed or unpaid
Chief prosecutor’s targets include ‘tax consultants who push dishonest avoidance schemes'
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Bulk settlement is needed to clear ‘huge backlog of cases’, says Jason Collins