INVESTIGATIONS

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).

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.

Steven Porter

Catherine Robins

Investigations are taking longer, but HMRC’s new facility offers multinationals the prospect of quicker resolution for certain disputes.

Adam Craggs

Constantine Christofi

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.

Clara Boyd

Ian Robotham

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.

Annis Lampard, Jenny Tevlin, Morgan Harries

Despite little change in the primary law, HMRC's practice over its information powers is changing due to continued pressure to increase tax yield and demands for data from its international counterparts, as experts at Deloitte explain.

Richard Jeens

Rose Swaffield

The 2019 loan charge teaches us that there is more to statutory time limits than the technical analysis, write Richard Jeens and Rose Swaffield (Slaughter and May).

Ben Jones

Kunal Nathwani

The international tax compliance landscape has become increasingly complicated and often unclear, as Ben Jones and Kunal Nathwani (Eversheds Sutherland) report.

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