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HMRC powers
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HMRC-POWERS
Private client review for May 2025
Sophie Dworetzsky
In this month’s review, Sophie Dworetzsky (Charles Russell Speechlys)
examines a case on distributions from an offshore company, a potentially farreaching
proposed change to the definition of permanent establishment and
the latest HMRC guidance.
Private client review for April 2025
Dominic Lawrance
Sophie Dworetzsky
They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance
(Charles Russell Speechlys) comment on the end of the remittance basis,
the ‘absolute mess’ that is the double remittance situation and a potentially
worrying change in HMRC’s view on the taxation of capital payments in
ancillary relief on divorce.
Impact Contracting Solutions Ltd v HMRC
HMRC’s power to deregister where VAT fraud
Navigating the protective assessment maze with Jeffries & Sons
Bryn Reynolds
Bryn Reynolds (Pinsent Masons) examines the recent
Jeffries
case which illustrates the potential taxpayer pitfalls surrounding protective assessments.
S Lefort v HMRC
Revocation of pension protection certificate.
EOTs: defending the indefensible or challenging the undefinable
David Alcock
Ritchie Tout
David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain
why these structures are increasingly under the spotlight.
At your disposal: conditionality under TCGA 1992 s 28
Rebekka Sandwell
Colin Askew
Rebekka Sandwell and Colin Askew (Eversheds Sutherland) consider the use of ‘conditional contracts’ in order to benefit from pre-Budget CGT rates.
K (oao UBS AG) v HMRC and another
HMRC must reconsider discretion not to apply PAYE obligations.
HMRC v HFFX LLP and others
CA holds that discretionary payments to LLP members were taxable as miscellaneous income.
The Oaks (Gatley) Ltd v HMRC
FTT dismisses taxpayer’s public law arguments against CIS determinations.
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 20 June 2025
Treasury unveils agile approach to tax consultations
HMRC update on capital allowances guidance project
Private school fees VAT challenge fails
HMRC confirm extended deadline for final VAT return
CASES
Read all
Eastern Power Networks plc and others v HMRC
A Moffat and another v HMRC
Performance Leads Ltd v HMRC
Other cases that caught our eye: 20 June 2025
Nellsar Ltd v HMRC
IN BRIEF
Read all
Lessons from Moran on the TOAA rules
IHT excluded property settlements
HMRC’s updated DOTAS guidance
Tax and PISCES
Tax reform and the growth agenda
MOST READ
Read all
Other cases that caught our eye: 13 June 2025
Tax reform and the growth agenda
Solent Pathway Campus Ltd v HMRC
The new UK PE, TP and UTPP rules: key questions
The Government amendments to domestic Permanent Establishment rules