Tax UK Notes

Insight alert: Exploring Labour's election tax plans

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 …

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 …

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 …

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 …

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 …

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 authorities) it can be a …

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, …