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HMRC
Measuring Tax Gaps 2023: analysis and predictions
Craig Kirkham-Wilson
Craig Kirkham-Wilson (Simmons & Simmons) examines
Measuring Tax Gaps 2023
and predicts more enforcement activity in relation to large businesses.
Impact Contracting Solutions Limited v HMRC
Can HMRC rely on a principle of EU law to cancel a VAT registration?
Scottish Power (SCPL) Ltd and others v HMRC
Payments in lieu of penalties are non-deductible.
HMRC’s evolving approach to tax compliance for the largest businesses
Nicole Newbury
HMRC’s large business director, Nicole Newbury, outlines the department’s approach, including priority areas of focus and how it is evolving to reflect wider changes in the economy and customers’ circumstances.
A tax on conscience? A moral dilemma for non-residents
Robert Waterson
Liam McKay
The Upper Tribunal has, for the first time, considered the meaning of ‘exceptional circumstances’ in the context of statutory residence – and it has set the bar extremely high, write Robert Waterson and Liam McKay (RPC).
Other cases that caught our eye: 8 September 2023
Calculating CJRS payments: We have seen a number of cases recently concerning the furlough (CJRS) scheme. Most of these have been about whether an employee meets the eligibility requirements. Ark Angel Ltd v HMRC [2023] UKFTT 705 (TC) (4 August 2023)...
JTIAC reaches the Upper Tribunal: onward, through the Slough of Despond, but for which purpose?
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) is disappointed by a recent Upper Tribunal decision on the unallowable purpose rule.
Judicial developments in recent treaty cases
Constantine Christofi
David Goldberg QC
Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).
HMRC v Part 26A: can you cram the Crown?
Abby Martin
Lisa Rickelton
Alex Lewis
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Nuel Oji
Stuart Walsh
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
Test-Chancellor outlines financial services strategy
HMRC manual changes: 18 July 2025
Chancellor outlines financial services strategy
CIOT reviews transfer pricing proposals
Marriage allowance: backdating claims
CASES
Read all
Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
B D’Angelin v HMRC
IN BRIEF
Read all
HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
MOST READ
Read all
‘Legislation Day’ date announced
G Haworth and others v HMRC
One Big Beautiful Bill Act enacted
Abbotsford Property Group Ltd and another v Revenue Scotland
Wealth taxes and fiscal reality