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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 …
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 …
Latest thinking from HMRC on offshore compliance
Within the framework of its "No Safe Havens" tax compliance strategy, HMRC has published two discussion papers concerning aspects of the administration …
SFO'S extra-territorial reach more limited than HMRC'S, at least for now
The Supreme Court has handed down judgment in the case of R (on the application of KBR, Inc) (Appellant) v Director of the Serious Fraud Office …
No litigation privilege in advice from accountants on tax structure
In a recent decision, the High Court has held that advice from accountants on a proposed new tax structure was not prepared for the dominant purpose of …
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 …
HSF Trust Companies Survey - Tax Insights
We asked trust companies questions about the most significant risk and compliance issues they face. The survey mapped which specific tax compliance …
Rapid resolution of domicile disputes: be careful what you wish for
In Henkes v HMRC [2020] UKFTT 7645 (“Henkes”), the First-tier (Tax) Tribunal (“the Tribunal”) held that (a) it could (and would) …
The extra-territorial reach of HMRC's investigatory powers
In R (on the application of Jimenez) v the First-tier Tribunal (Tax Chamber) and HMRC ("Jimenez"),1 the Court of Appeal determined that HMRC had …
Limitation on who is a "Relevant Data Holder": a snoop too far?
Wilsons Solicitors LLP v HMRC ("the Wilsons case")1 is an interesting decision of the First-tier Tribunal (Tax Chamber) ("FTT"). It arises …
When can trustees assert privilege?
Recording: Originally broadcast: 31 October 2017 Faced with requests for disclosure (including from regulators and tax …
HMRC's Evasion and Avoidance Strategy: what you need to know
Recording: Originally broadcast Tuesday 5 September 2017 This webinar focussed on recent developments in relation to …
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