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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 …
What is "reasonable detail" when notifying a tax claim under an SPA?
In Dodika Limited (and others) v United Luck Group Holdings Limited [2021] EWCA Civ 638, the Court of Appeal held that the Defendant had complied with …
Danish WHT fraud claim dismissed
The High Court in Skatteforvaltningen v Solo Capital Partners LLP & Ors [2021] EWHC 974 (Comm) ("Solo Capital") has dismissed claims brought by the …
HMRC's ability to argue fraudulent misrep hindered
In IGE USA Investments Limited v HMRC [2021] EWCA Civ 534, the Court of Appeal overturned part of an interlocutory decision of the High Court dealing …
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 …
Notification of Uncertain Tax Treatment - our response to the Consultation
In March 2020 Her Majesty’s Revenue and Customs (“HMRC”) released a consultation document (the "ConDoc") regarding a new proposal to bring forward …
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