TAX POLICY ADMINISTRATION

Ray McCann

Small businesses remain HMRC’s principal compliance target, but tackling non-compliance will require more than enforcement, argues Ray McCann.

Emily Osborne

‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.

Jenny Batchelor

Ahmed Mobasshir

The UK’s legal framework offers statutory and non-statutory clearances, CCMs, APAs and the forthcoming Advance Tax Certainty Service, but these mechanisms fall short in practice, write Jenny Batchelor and Ahmed Mobasshir (Ryan).

Jenny Tragner

Ali Shokoohi

Promising but flawed? Jenny Tragner and Ali Shokoohi (S&W) examine HMRC’s SME R&D assurance pilot, which offers earlier answers on difficult points but whose lengthy form-led design may create fresh uncertainty.

Liesl Fichardt Emily Au Julius Konstantin Berling

Who proves what? Liesl Fichardt, Emily Au and Julius Konstantin Berling (Quinn Emanuel) set out how penalty appeals now divide the burden between HMRC and the taxpayer – and why the line between the two is far from settled.

A practical guide by Lexis®+ UK Tax examining when a non-statutory clearance is the right route, how to frame the application and how far HMRC’s response can be relied upon.

Georgia Hicks

Following the remitted PGMOL decision, barrister Georgia Hicks (Devereux Chambers) explores where the employment status battleground now lies, and why the third stage of the RMC test has become more important than ever.

Daria Nikitina

Simon Down

Benefit in kind rates remain attractive for electric vehicles, but are only part of the picture. Simon Down and Daria Nikitina (Deloitte) explain why employers should adopt a total cost of operation approach to fleet strategy.

Waqar Shah

HMRC have indicated that they intend to update their litigation and settlement policy later this year. Waqar Shah (Kingsley Napley) considers why the policy is ripe for change.

Kyle Rainsford

What happens when tax planning appears to exploit a loophole? Kyle Rainsford (Addleshaw Goddard) reviews the courts’ anti-avoidance toolkit following the HC-One SDLT ruling.

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