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When can a partial closure notice be required?
In Embiricos v HMRC [2022] EWCA Civ 3, the Court of Appeal confirmed that where HMRC's conclusion in respect of a matter enquired into has computational …
Estoppel by convention and notices of enquiry
In Tinkler v HMRC [2021] UKSC 39, the Supreme Court held that a taxpayer (Mr Tinkler) was prevented (estopped by convention) from challenging the …
Kandore: information notices and the limits of open justice
HMRC's powers under Schedule 36 Finance Act 2008 ("Schedule 36") to obtain information relating to a taxpayer's affairs from a third party are …
Supreme Court provides guidance on Follower Notices
In R (on the application of Haworth) v HMRC [2021] UKSC 25, the Supreme Court has upheld the Court of Appeal's decision quashing a follower notice issued …
Supreme Court rules on what is "deliberate"
The Supreme Court has dismissed the Revenue's appeal in HMRC v Tooth [2021] UKSC 17, a case concerning whether a "discovery assessment" was validly made …
DAC 6 Reporting Deferred in the UK
The UK government has today announced that the first reporting deadline under DAC 6 will be deferred for 6 months to allow taxpayers and advisors …
Tax Appeals: Don't Forget ADR
The President of the First-tier Tribunal (Tax) (the "Tribunal”) has today published a practice statement (the “Statement”) on the Tribunal’s approach to …
Discovery Assessments after Tooth: it's never too late, it seems
Where a loss of tax has been brought about deliberately by a taxpayer, the time limit for HMRC to raise a discovery assessment is increased from 4 years …
Disclosure of VAT and Indirect Tax Avoidance Schemes
New disclosure obligations in relation to VAT and all indirect taxes were introduced with effect from 1 January 2018. The disclosure obligation will …
When can trustees assert privilege?
Recording: Originally broadcast: 31 October 2017 Faced with requests for disclosure (including from regulators and tax …
Privilege: to what is HMRC entitled?
HMRC are not entitled to compel taxpayers or third parties to provide information or documentation that is subject to legal professional privilege, …
The Limits of HMRC's Powers of Investigation
In support of HMRC's powers to enquire into and investigate taxpayers' affairs, Parliament has conferred upon HMRC powers to require taxpayers and third …
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