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Latest updates and insights from our experts in tax dispute resolution.
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 have escaped Part 7A anyway. The GAAR appears to have been applied in advance of a 'normal' assessment and appeal process,...
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 dealing with tax disputes. Both cases form part of what is becoming an ongoing series dealing with High Income Child...
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 are a few steps forward and a few steps back. There’s also lots to do before the (now absolutely fixed) 30 September...
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 are: Employee Benefit Trusts and EFRBS Dispute Resolution and ADR The Finance Act 2017 Corporate Criminal Offence CJRS...