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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...
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
HMRC will initiate an investigation under their Code of Practice 9 (COP9) in cases where they suspect tax fraud. HMRC does not usually disclose what...
GAAR Panel Ruling– can we get rid of Part 7A now (please)?
By Jon Preshaw 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...
Tribunal criticises HMRC – Is there a reasonable excuse?
By Jon Preshaw Two recent cases decided last month, Belloul [2020] UKFTT 312 (TC) and Jacques [2020] UKFTT 311 (TC) contain some really helpful...
Loan charge guidance – the fog clears (a bit)
By Jon Preshaw HMRC have now published guidance on the implications of the Finance Act 2020 changes for ongoing disputes and settlement discussions....
HMRC coming out of lockdown – 6 things to look out for
By Jon Preshaw Now that HMRC are recommencing compliance activity, there are six key issues which I think they’ll be focussing on over the coming...
Disguised Remuneration Loan Charge – is it time to act?
By Jon Preshaw HMRC’s 'pause' on compliance activity now appears to have ceased. One of the consequence of this is that a number of my clients have...