On or off the record?
Under FA 2008 Sch 36, an HMRC officer may, by notice in writing (‘an information notice’), require the taxpayer, or a th...
Under FA 2008 Sch 36, an HMRC officer may, by notice in writing (‘an information notice’), require the taxpayer, or a th...
On 13 April 2016 the Court of Appeal’s decision that Eclipse Film Partners No.
Imagine a client coming in with this great tax-saving idea.
Using evidence to inform policy is a key mantra of modern government, not least when it comes to developing tax policy....
When the OECD’s Base Erosion and Profit-Shifting (BEPS) action plan was announced, Action 14 (making dispute resolution ...
After many years, enquiry closure notices as we know them are on the ‘endangered species’ list as a result of the FB 201...
A December 2015 report from the National Audit Office contained the following: ‘HMRC agreed a target to increase the num...
In my April 2013 article in Tax Adviser ‘Much Ado about Something’, I wrote about the appeal by JP Whitter (Waterwell En...
There’s little doubt that public country-by-country reporting is an emotive topic for tax campaigners....
De Beers: the case law test De Beers Consolidated Mines Ltd v Howe (Surveyor of Taxes) 5 TC 198 is often quoted as auth...