HMRC POWERS

Guy Bud

Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision which stresses the need for accountability and transparency from HMRC when issuing determinations.

Richard Doran

John Hayton

Principled positions often adopted by HMRC can have the practical effect of avoiding or otherwise delaying judicial scrutiny of their decision-making process, write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).

Liesl Fichardt

Emily Au

HMRC’s preferential ranking brings into sharp focus their requirements to evidence and substantiate their claims in an insolvency, as Liesl Fichardt and Emily Au (Quinn Emanuel) explain.

Thomas Wilkinson

Kate Garcia

Kate Garcia and Thomas Wilkinson (Shoosmiths) review the consultation on the potential redesign or reform of penalties imposed for inaccuracies in tax returns and failures to notify.

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) examine the current consultation which could help influence HMRC’s future approach to dispute resolution.

Michael Paulin

Michael Paulin (1 Crown Office Row) considers the impact of HMRC’s broader view of tax fraud in its updated COP 9.

Malcolm Gammie CBE KC

Malcolm Gammie CBE KC (One Essex Court) examines recent Government proposals which, he says, leave little doubt that tax avoidance, like tax evasion, is to be regarded as a criminal activity.

Daniel Williams

Michelle Sloane

A recent High Court decision provides valuable guidance for taxpayers seeking to challenge enforcement action taken by HMRC’s Debt Management team, write Michelle Sloane and Daniel Williams (RPC).

James Dudbridge

HMRC’s updated guidance marks the end of a long and winding road for R&D claimants and their advisers, writes James Dudbridge (ForrestBrown).

Heather Self

Political pressure has resulted in HMRC adopting a slow and cautious decision-making process that remains to this day, writes Heather Self (Blick Rothenberg).

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