The monthly review of tax issues affecting the City, by Mark Middleditch (Allen & Overy).
Consequences of breaching an order of the tax tribunals
Discovery assessments and enquiries into returns
BPP v HMRC tells us that HMRC must comply with rules and directions issued by the tax tribunals, reports Robert Waterson (RPC).
VAT periods and repayment claims
Applicability of the payment on account regime
Unsolicited returns
Tax advisers are going to be required by law to inform their clients about the dangers of not declaring offshore income using wording specified by HMRC. No harm in that, you might think, but where does it end?
Jonathan Hare, Stephen Morse (PwC) and Peter Halford (PwC Legal) answer the key questions on the European Commission’s investigations into alleged illegal state aid as a way of tacking perceived corporate tax avoidance.
Michael Anderson and Katy Howard (Joseph Hage Aaronson) review the decision in Scotch Whisky, which provides helpful guidance on how a national court should apply the proportionality test in an EU law context.