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Hmrc
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Hmrc
HMRC
HMRC v Part 26A: can you cram the Crown?
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.
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Stuart Walsh
Nuel Oji
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
Ebuyer (UK) Ltd v HMRC
HMRC barred from proceedings for non-compliance with unless order
Other cases that caught our eye: 28 July 2023
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...
A tougher approach at HMRC, but at what cost?
Ray McCann
Consultant and former CIOT president Ray McCann discusses the limitations of HMRC’s recent compliance strategy and suggests a more pragmatic approach.
Due diligence on acquisitions of UK REITs
Rob Williams
Rob Williams (FTI Consulting) reviews the dangers of not getting it REIT.
HMRC v J Conran; JC Vision Ltd v HMRC
Payment for asset transfer between connected parties was a distribution
Laing O’Rourke Services Ltd v HMRC; HMRC v Willmott Dixon Holdings Ltd
NICs on car allowances
Other cases that caught our eye: 14 July 2023
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...
Civic Environmental Systems Ltd v HMRC
Disregarding carry-back loss claim in closure notice appeal.
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EDITOR'S PICK
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
1 /7
What happens at a tribunal hearing?
Anne Redston
2 /7
Schedule 36: a stitch in time
Keith Gordon
3 /7
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
4 /7
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
5 /7
Tax Administration and Maintenance Day: report
6 /7
Pension planning after the Budget
Mike J Haynes
7 /7
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
What happens at a tribunal hearing?
Anne Redston
Schedule 36: a stitch in time
Keith Gordon
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
Tax Administration and Maintenance Day: report
Pension planning after the Budget
Mike J Haynes
NEWS
Read all
Treasury Committee calls for systematic review of tax reliefs
NICs investment zone reliefs for employers
R&D claim requirements confirmed
New transfer pricing records requirements
HMRC issues clarifications on SBAs
CASES
Read all
M R Currell Ltd v HMRC
Sonder Europe Ltd v HMRC
TP v Administration de l’Enregistrement, des Domaines et de la TVA
Ebuyer (UK) Ltd v HMRC
Other cases that caught our eye: 28 July 2023
IN BRIEF
Read all
Self’s assessment: Inheritance tax
When does a payment constitute a distribution?
OECD inclusive framework publishes outcome statement on Pillar One and Pillar Two
Legislation day: practitioners' views
Challenging information notices
MOST READ
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