HMRC POWERS

Ian Hyde

Matthew Greene

Ian Hyde and Matthew Greene (Osborne Clarke) discuss HMRC’s data-gathering powers that provide an effective tool to police the gig economy.

Keith Gordon

The loan charge has driven a coach and horses through the statutory safeguards, writes barrister Keith Gordon (Temple Tax Chambers).

Helen Adams

Recent decisions reinforce that HMRC is empowered to request information and investigate taxpayers’ positions without using statutory enquiry or information powers, writes Helen Adams (BDO).

Despite the review being an important event, it appears to be very much business as usual at HMRC.

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.

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.

Lee Ellis

Cristiana Bulbuc

Hyrax and Curzon Capital Ltd consider for the first time the provisions governing HMRC’s ability to seek an order that a scheme is notifiable under DOTAS. Lee Ellis and Cristiana Bulbuc (Stewarts Law) consider the practical implications.