APPEALS

Adam Craggs and Constantine Christofi (RPC) consider the recent spate of IR35 cases that have been considered by the First-tier Tribunal, HMRC's increasing use of 'jeopardy amendments' and the increasing number of judicial review challenges being brought against HMRC.  

The judgment in Tooth increases the weight of authority behind the issue of 'staleness', but that concept is not yet settled.

Although the Court of Appeal decided that HMRC had not made a discovery, the judgment contains unhelpful comments for taxpayers, as Clara Boyd and Ian Robotham (Pinsent Masons) explain.

In J Dickinson and others v HMRC [2018] EWCA Civ 2798 (18 December 2018), the Court of Appeal upheld the High Court’s decision not to grant judicial review of APNs (FA 2014 s 219) issued by HMRC, despite an earlier promise not to enforce payment...

In K Tutty v HMRC [2019] UKFTT 3 (31 December 2018), the FTT found that a discovery made following the use of an electronic standard information package (‘E-SIP’) was not stale. Ms Tutty had implemented arrangements to avoid SDLT and HMRC had issued...

HMRC has advised it may not be able to meet its target response times for acknowledging disclosures made by taxpayers via the worldwide disclosure facility for UK tax liabilities relating to offshore matters, owing to ‘an increase in the number of disclosures received’.

HMRC is consulting until 11 February 2019 on the draft Income Tax (Construction Industry Scheme) (Amendment) and the Corporation Tax (Security for Payments) Regulations 2019, extending the scope of the existing security deposits legislation to include construction industry scheme and corporation

The chancellor has announced the appointment of Bill Dodwell to succeed Paul Morton as tax director of the Office of Tax Simplification (OTS).

In Supaglazing v HMRC [2018] UKFTT 712 (10 December 2018), the FTT found that discovery assessments issued by HMRC were valid as the taxpayer had been careless (FA 1998 Sch 18). Mrs Jones was the majority shareholder, company secretary and a director...

HMRC will shortly begin sending letters to those businesses it has identified as falling within the group permitted to defer compliance with making tax digital (MTD) until October 2019.