Criticism of HMRC’s failure to prosecute HSBC Swiss tax evaders has been quite unfair, writes Jonathan Fisher QC (Devereux Chambers). There are problems with criminal prosecution and the decision to focus on tax collection through civil settlement is the right one. It makes little sense to criminally prosecute these cases.
The penalty for late self-assessment filing needs rethinking. HMRC's recent discussion document looks promising, writes Paul Aplin.
Following the allegations and outcry in recent weeks over tax evasion involving HSBC’s Swiss bank accounts and criticism of HMRC’s activities when the information was handed to them in 2010, shadow chancellor Ed Balls tabled an urgent question on tax avoidance and HSBC in the House of Commons on
The substantial shareholdings exemption is in danger of being misunderstood, warns Heather Self (Pinsent Masons)
Andrew Goldstone and Charlie Sosna (Mishcon de Reya) round up the latest private client news, including: the remittance basis charge consultation; a report on tax incentives for art; Hutchings; and BiGDUG Limited Remuneration Trust (from Guernsey)
HMRC has announced that the Court of Appeal has ruled in its favour against Eclipse Film Partners (No 35) LLP, which it said ‘protected an estimated £635m in tax’.
Following the censure HMRC received over the HSBC ‘Swiss leaks’ before the Public Accounts Committee on 11 February, as well as further press criticism, HMRC issued a statement on when and how it came by the leaked HSBC Suis
HMRC has issued guidance about PAYE reporting requirements for employment intermediaries.
Tori Magill (Pinsent Masons) answers a query on a client who participated in a marketed avoidance scheme and has received a COP9 notice
In this month’s briefing, Mark Middleditch (Allen & Overy) provides a round-up of recent tax developments affecting the City, including: the decisions in Sir Fraser Morrison (contingent CGT liability for shareholder-director) and Project Blue (SDLT anti-avoidance); new tax relief for corporate rescues; and the Office of Tax Simplification’s report on partnership taxation.