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INVESTIGATIONS


HMRC is pedalling lightly on some aspects of tax investigations during the current Covid-19 pandemic, but that does not mean that potential tax liabilities have been forgotten.
Despite its critics, the COP 9 process appears to be here to stay. Sarah Stenton and Lisa Vanderheide (Stewarts) provide practical insights for advisers.

This year has seen an increasing compliance burden for companies, an expansion of HMRC powers and a reminder of the important role of the courts, write Kate Ison and Jessica Hocking (Bryan Cave Leighton Paisner).

Ami Jack (Smith & Williamson) sets out a guide to the main political parties’ tax proposals in the run-up to the general election.
The government intends to change the law retrospectively to make it clear that HMRC can use automated processes to issue notices to file returns and to issue penalties, report Catherine Robins and Steven Porter (Pinsent Masons).
Ian Hyde and Matthew Greene (Osborne Clarke) discuss HMRC’s data-gathering powers that provide an effective tool to police the gig economy.

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

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 (Temple Tax Chambers) argues that outstanding loan charges should be pursued both as a matter of law and social policy.
We now have two recent opposing tribunal judgments on how the partial closure notice rules operate, writes Craig Thomson (Grant Thornton).
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