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HMRC powers
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HMRC powers
HMRC-POWERS
Private client review for November 2021
Georgia Rawlinson
Edward Reed
Edward Reed and Georgia Rawlinson (Macfarlanes) provide this month’s review of developments affecting private clients.
HMRC’s updated SAO guidance: a focus on the main duty
Laura Harper BDO
Jason Land
Jason Land and Laura Harper (BDO) examine HMRC’s updated guidance on
SAO qualifying businesses.
Embiricos and the future of partial closure notices
Catrin Harrison
Hugh Gunson
Dominic Lawrance
Catrin Harrison, Dominic Lawrance and Hugh Gunson (Charles Russell Speechlys)
examine an Upper Tribunal decision that is disappointing for taxpayers and
removes a strategic weapon for anyone faced with a domicile enquiry.
Litigation privilege and structuring advice
Dominic Stuttaford
Tax structuring advice received and implemented, even where there is a
perceived risk of challenge, will not benefit from litigation privilege, writes
Dominic Stuttaford (Norton Rose Fulbright).
Notifying HMRC of uncertain tax treatments: transparency or confusion?
Matthew Greene
Ian Hyde
Ian Hyde and Matthew Greene (Osborne Clarke) examine the government’s plans to require large businesses to notify HMRC of uncertain tax treatments they have adopted after April 2021.
Contentious tax: quarterly review
Constantine Christofi
Adam Craggs
Adam Craggs and Constantine Christofi (RPC) review recent developments over the course of the past three months.
HMRC powers: the new professional standards committee
Paul Aplin OBE
Paul Aplin OBE (A C Mole & Sons) welcomes proposals for a new professional standards committee.
Self's assessment: will the UK become a tax haven after Brexit?
Heather Self
It seems unlikely, writes Heather Self (Blick Rothenberg).
No safe havens 2019: HMRC’s renewed focus on offshore non-compliance
Jessica Hocking
Kate Ison
Kate Ison and Jessica Hocking (Bryan Cave Leighton Paisner) examine the key findings and implications from two policy papers published at the time of the Spring Statement.
Tax and the City review for March 2019
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
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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