HMRC-ENQUIRIES

Steven Porter and Penny Simmons (Pinsent Masons) provide guidance for large businesses on managing IR35 compliance risks.

Sophie Rhind

It is encouraging to see the FTT dealing robustly with situations where HMRC fail to discharge their burden of proof, writes Sophie Rhind (Macfarlanes).

Edward Reed

Emma Critchley

Edward Reed and Emma Critchley (Macfarlanes) recap the key private clients announcements in the Spring Budget, and they report some interesting procedural points when challenging HMRC enquiries.

HMRC’s retention and internal sharing of copy documents obtained during criminal investigation.

Information notice requiring email searches was valid but disclosure request held to be too broad.

Upper Tribunal dismisses challenges to accelerated payment notices.

Goodwill: M Smith and another v HMRC [2023] UKFTT 912 (TC) (30 October 2023) is an interesting case on the nature of goodwill. Two individual IFAs operated via a company. The business of the company was transferred to an LLP and the capital accounts...

Peter North

Richard Sultman

While awaiting the outcome of HMRC’s consultation on stamp tax modernisation, Richard Sultman and Peter North (Cleary Gottlieb) consider some missed opportunities and unresolved issues.