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HMRC’s overall aim is simple: to make it easier for customers to pay the right amount of tax at the right time.

One of the interesting phrases used in the recent consultation, Improving Large Business Compliance, is ‘the spirit of the law’.

Practitioners will be familiar with the concept of culpability principally in the context of HMRC enquiries into the accounts of a trading business.

For most tax advisers, the mere mention of judicial review sends shivers down the spine. There is a fear of increased costs and complexity and, for non-lawyers, the need to find a solicitor.

No one knows the true scale of tax evasion.

The CIOT and ATT’s survey of members in February 2015 was their first in five years to seek views on on HMRC Powers: Penalties, Compliance Checks and Reviews.

The acquisition of an asset and its subsequent lease back to the vendor is known as a sale and leaseback (S&L) transaction.

It is often the case that a tax dispute is resolved between HMRC and the taxpayer by mutual agreement; that is, without the matter being formally determined by the tribunals or the courts.

Most commentary on the practicalities of accelerated payment notices (APNs) dates to the period of a ‘phony war’, when the legislation was in force but HMRC were still marshalling their troops.

HMRC charge tax-geared penalties for errors in tax returns.