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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 is a trust not a trust?
Recording: Originally broadcast: 17 November 2017 The recent English High Court decision in the latest round of the Pugachev …
Supreme Court denies compound interest in taxpayer's claim against HMRC
In Littlewoods Ltd and others v HMRC [2017] UKSC 17, the Supreme Court delivered a controversial decision allowing HMRC's appeal, which means that …
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 …
Getting Justice in the Tribunal
This note is principally about two Supreme Court cases, R (on the application of UNISON) v Lord Chancellor [2017] UKSC 51 ("the fees case") and BPP …
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 …
VAT and defined benefit schemes: taxing times ahead
It is more than three years since the European Court ("CJEU") rulings in Wheels and PPG, in which the CJEU found that (a) the supply of investment …
New UK criminal offences of failing to prevent facilitation of tax evasion
In our October 2016 briefing, we reported on the publication of the Criminal Finances Bill 2016–17. The Bill introduces a range of new measures to fight …
Alternatives to Litigation
HMRC is responsible for the collection and management of tax in the UK. It has a wide discretion in doing so, and in how it goes about litigating …
Do settlement agreements bind HMRC?
In the course of giving oral evidence to the Public Accounts Committee (the "PAC") in relation to the well-publicised settlement agreement concluded with …
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