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INSIGHTS
Read our regular newsletter, highlighting recent developments in the law & practice around Tax Disputes & Investigations.
Tax Disputes and Investigations – January 2023
HMRC ‘Nudge’ Letters HMRC have kicked off 2023 with yet another batch of nudge letters. This round of letters targets taxpayers who they suspect...
Tax Disputes and Investigations – December 2022
Electronic Sales Suppression and Disclosure Facility HMRC have arrested five people suspected of being behind a multimillion-pound global fraud...
Offshore companies with UK property – update
HMRC have confirmed that they will be undertaking a campaign to address non-compliance with UK tax legislation by companies established outside the...
HMRC nudge letters
HMRC will shortly begin issuing letters to non-UK companies which own UK property. There will be two types of letter – Letters to companies which...
Code of Practice 9 enquiries and how we can help
What is Code of Practice 9? HMRC will initiate an investigation under their Code of Practice 9 (COP9) in cases where they suspect tax fraud. HMRC...
HMRC interest and claims to mitigate
GAAR Panel Ruling– can we get rid of Part 7A now (please)?
This GAAR panel ruling can’t have been a surprise to anyone. However, I can’t really see any basis on which the transactions could realistically...
Tribunal criticises HMRC – Is there a reasonable excuse?
Two recent cases decided last month, Belloul [2020] UKFTT 312 (TC) and Jacques [2020] UKFTT 311 (TC) contain some really helpful material for those...
Loan charge guidance – the fog clears (a bit)
HMRC have now published guidance on the implications of the Finance Act 2020 changes for ongoing disputes and settlement discussions. As ever, there...
HMRC coming out of lockdown – 6 things to look out for
Now that HMRC are recommencing compliance activity, there are six key issues which I think they’ll be focussing on over the coming months. These...