Taxpayers increasingly need to rely on statements made by HMRC which do not have the force of law, such as HMRC clearances given to a taxpayer or HMRC guidance. In this back-to-basics guide, Christopher Harrison and David Stainer (Allen & Overy) provide an overview of the principles which govern a taxpayer’s ability to rely on written statements by HMRC, particularly on legitimate expectation.
Andrew Goldstone and Sarah Albury (Mishcon de Reya) report on recent updates in the private client arena, including: the proposed new strict liability criminal offence; changes to the LDF; the common reporting standard in the UK; strengthening DOTAS and the VADR; and the Presumption of Death Act.
Angela Savin (Norton Rose Fulbright) examines HMRC’s recent guidance on its new powers in this year’s Finance Act.
Go directly to jail; do not pass ‘go’; do not collect £200. Is HMRC’s approach getting out of hand, asks Peter Vaines, partner, Squire Patton Boggs
HMRC has restricted the availability of the Liechtenstein disclosure facility (LDF). The restrictions are subject to three key exclusions; these are not as clear cut as one might think, writes Simon Airey, head of tax investigations, DLA Piper
James Bullock considers how effective the new ‘accelerated payments’ powers granted to HMRC will be in curbing tax avoidance schemes.
HMRC has published a tax information and impact note on the new rules which will allow it to issue conduct notices to promoters of tax avoidance schemes. The note stresses that these rules have effect since Royal Assent of the Finance Bill (i.e. 17 July 2014).
Tori Magill reviews the changes to the contractual disclosure facility (CDF), and considers the impact for clients
Isobel Clift answers a query on HMRC information powers and close company enquiries
Property searches by HMRC to target tax evasion jumped by 12% in the last year to 500, up from 445 property raids in 2012/13, according to data obtained by law firm Pinsent Masons. This is more than triple the number of property raids that HMRC undertook each year between 2008 and 2011.