HMRC is consulting on the enactment of ESC D33. Paul Howard (Gabelle) reports.
HMRC has restricted the availability of the Liechtenstein disclosure facility (LDF). The restrictions are subject to three key exclusions; these are not as clear cut as one might think, writes Simon Airey, head of tax investigations, DLA Piper
The CIOT has welcomed the passing of the Revenue Scotland and Tax Powers Bill by the Scottish Parliament. The Bill means that Scotland now has the legal framework to operate its own tax authority for devolved taxes.
Late withdrawal of case by HMRC
Avoidance involving the transfer of assets to Gibraltar
Reasonable excuse
Reasonable excuse and special circumstances
Burden of proof in a refund claim