COMPLIANCE

Gideon Sanitt (Macfarlanes) examines the decision in Ingenious that provides some guidance as to how courts might determine whether there is a genuine commercial trading arrangement with a view to profit.

The UK has published draft regulations adopting an EU directive that promises faster resolution of double taxation disputes between member states.

Adam Craggs

Michelle Sloane

In this quarterly review, Adam Craggs and Michelle Sloane (RPC) consider HMRC’s increasing propensity to seek the production of documents from accountants and other professional advisers, HMRC’s new policy of challenging taxpayers’ loan relationships, and the increase in the number of domicile enquiries launched by HMRC.

David Pett

David Pett (Temple Tax Chambers) argues that outstanding loan charges should be pursued both as a matter of law and social policy.

Matthew Hodkin

Susie Brain

Matthew Hodkin and Susie Brain (Norton Rose Fulbright) consider HMRC's proposed approach to implementation and how reporting is likely to work within the context of the UK tax system.

Robert O'Hare

Jefferson VanderWolk

Robert O’Hare and Jefferson VanderWolk (Squire Patton Boggs) review the operation of the draft rules and speculate on their implementation.

Zoe Andrews

Zoe Andrews (Slaughter and May) takes a first look at the UK draft regulations implementing the EU's cross-border reporting rules.

Craig Thomson

We now have two recent opposing tribunal judgments on how the partial closure notice rules operate, writes Craig Thomson (Grant Thornton).

Michael Thomas KC

Barrister Michael Thomas (Pump Court Tax Chambers) believes there is a disturbing trend in our tax jurisprudence: an increasing number of important decisions made by HMRC are only capable of being challenged on a judicial review basis.

Helen Adams

Recent court decisions suggest that the meaning of 'deliberate' behaviour now differs for ‘discovery’ assessments compared to penalties for errors, writes Helen Adams (BDO).

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