HMRC has no automatic right to a stay in civil proceedings where a criminal investigation commences. Michael Avient and Heather Williams review the decision in Mr Swallow v HMRC
James Bullock identifies the 2010 developments affecting tax dispute resolution
Simon Norris, Head of HMRC Powers, and leading private sector tax professionals Phil Berwick, Kevin Igoe and Aileen Barry took part in a Tax Journal round table discussion on HMRC powers
Simon Whitehead considers whether the Upper Tribunal’s guidance on the ability to recover costs will comply with EU law
Ashley Greenbank considers legal privilege following the decision in Prudential
Adam Craggs and Jonathan Wood look at the Australian and US mediation experiences, and ask if they offer any lessons for the UK
The flood of Fleming-claims shows no signs of abating. David Southern examines the legal issues
Richard Clarke and Hannah Foulkes examine the effectiveness of recent HMRC initiatives
HMRC has admitted that guidance setting out when it will consider a person’s domicile, and decide whether to make a determination of inheritance tax based on that domicile, has not been working well for HMRC or taxpayers.
‘There's absolutely no question of HMRC softening its approach to tackling avoidance, and HMRC will continue to ensure that everyone pays the right tax,’ a spokesman told Tax Journal after reports suggested that tax officials were to take a softer stance on avoidance.