Taxpayers should think about the consequences before agreeing to HMRC’s latest initiative to further influence taxpayer behaviour, writes Michael Avient (UHY Hacker Young).
Robert Waterson (RPC) reviews guidance from the Court of Appeal on the meaning of ‘sham’.
Tori Magill (Pinsent Masons) answers a query on the validity of a discovery assessment received by a taxpayer who participated in a marketed tax avoidance scheme.
Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including the latest proposals on tackling tax evasion and avoidance; the EU’s tax transparency measures; and recent cases illustrating the limits of the purposive approach.
Gideon Sanitt (Macfarlanes) considers the decision in Ingenious Media and when HMRC may be excused from its duty of confidentiality.
David Pickstone (Stewarts Law) reviews the recent Upper Tribunal decision in Ingenious, which considered whether HMRC could make allegations of dishonesty at a late stage in proceedings without having pleaded them in its statement of case.
The Treasury has published its proposed next steps on tackling evasion and avoidance. James Bullock (Pinsent Masons) reviews the detail.