INVESTIGATIONS

Four recent commentaries examine different aspects of the tax compliance landscape.

Kate Ison

Kate Ison (Bryan Cave Leighton Paisner) reviews the department’s strategy.

Stuart Walsh

Jason Collins and Stuart Walsh (Pinsent Masons) review a recent tribunal case which highlights the practical difficulties of asserting legal privilege where the taxpayer has to explain their motivations behind a transaction.

Clare Reeve Curatola

Kate Ison

The decision in Bilta has clarified the scope of privilege in internal investigations undertaken in the context of HMRC enquiries, write Kate Ison and Clare Reeve (Berwin Leighton Paisner).

Patrick Cannon

HMRC needs to exercise more care when applying for search and seizure warrants, writes Patrick Cannon (15 Old Square Tax Chambers).

Jason Collins

Large companies should refresh their raids and critical incident procedures in the event that HMRC decides to investigate, writes Jason Collins (Pinsent Masons).

Richard Jeens

Richard Jeens (Slaughter and May) considers the additional pressures on tax authorities to tackle evasion and avoidance, and how this promises not only more, but more intense tax enquiries and litigation for taxpayers; as well as identifying new tools added to HMRC’s repertoire, such as the new partial closure notice provisions.

Chris Davidson

The report published last month contains some fascinating detail which throws a light on how HMRC is approaching the task of settling large disputes, writes Chris Davidson CBE (KPMG).

Gideon Sanitt

Corporates are facing the regulatory scrutiny once reserved for banks. Gideon Sanitt (Macfarlanes) considers the treatment of the costs of such investigations.