Damiano Sogaro and Gideon Sanitt (Macfarlanes) review recent litigation on the tribunal's role in determining domicile issues when considering challenges to an enquiry or to information notices.
HMRC is consulting on changes to the powers which it has to obtain documents from third parties, such as banks, when investigating somebody's tax affairs. The proposals have generated much adverse comment in the media because they would remove safeguards which currently exist to prevent HMRC from using its powers indiscriminately.