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HMRC


Card image Lisa Rickelton, Alex Lewis, Abby Martin
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report. 
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
HMRC barred from proceedings for non-compliance with unless order
Petroleum revenue tax (PRT) and subsidiary argumentIn HMRC v Perenco UK Ltd [2023] UKUT 169 (TCC) (19 July 2023), the UT dismissed HMRC's appeal against the FTT decision. Consequently, expenditure incurred by the taxpayer during the relevant period...
Consultant and former CIOT president Ray McCann discusses the limitations of HMRC’s recent compliance strategy and suggests a more pragmatic approach.
Rob Williams (FTI Consulting) reviews the dangers of not getting it REIT.
Payment for asset transfer between connected parties was a distribution
VAT penalties:Aizio Associates Ltd and others v HMRC [2023] UKFTT 576 (TC) (29 June 2023) is in many ways a straightforward case about penalties for incorrect VAT returns. It does have one point of interest, however. Could HMRC charge a penalty where...
Disregarding carry-back loss claim in closure notice appeal.
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