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Currently, the legislation allows HMRC to assess the second late payment penalty once, when the amount of outstanding tax is paid in full, within a two-year assessment time limit.

In recent years, HMRC have been increasing their use of one to many (OTM) letters in their compliance approach.

HMRC say that Ocelot is more user-friendly for caseworkers, setting out information on a single platform with task-based procedural guidance that is easier to follow than the manual format.

A fundamental aspect of the tribunals system is that a tribunal is meant to be a more accessible forum for achieving justice than the courts.

A May 2024 survey by Tolley found that two-thirds of UK tax practitioners are regularly using generative AI or are planning to do so soon.

Just a few days after this article appears, a new government will be formed to lead the country for the next five years.

All professionals want happy clients who pay their fees on time, refer more work to them, and go on to refer them to other potential clients. Fee disputes cause significant problems, however.

Over the last few months, I’ve had the pleasure of presenting a series of online sessions to students and members of the ATT and CIOT entitled ‘The thriving tax professional’.

Members may be asked by clients or potential clients to provide advice, guidance and support to enable the person or business to make a disclosure to HMRC.

The call for evidence is on the GOV.UK website: tinyurl.com/2p9km4sz