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I have been working in the tax profession for over 26 years and it is fair to say that I have seen quite a number of changes in that period.

The tide has undoubtedly gone out so far as such arrangements are concerned.

The ADR deficit

It is well known that the Tribunal system is under increasing pressure and often overwhelmed with cases that need not have ever seen the light of day in an adversarial set

A client undertook tax planning which is now the subject of HMRC attention, and the adviser needs to make representations to HMRC. Ahead of doing so, the adviser:

The arrival of Self Assessment more than 20 years ago meant that most challenges by (what is now) HMRC into a taxpayer’s income tax, capital gains tax or corporation tax position should be undertak

Cryptocurrency – the future of e-vasion?

If you don’t know what Bitcoins are, you can take comfort from the fact that you are not alone.

The Court of Appeal’s decision in R (on the application of Rowe and Others) v HMRC [2017] EWCA Civ 2105 finally offers some reassurance that the Revenue does not have completely free rein

Successive UK governments have been clear about their goal of increasing and encouraging tax transparency and this trend for greater transparency is also reflected in the agendas and action plans o

The curtain comes down

Disguised Remuneration (DR) arrangements involve a payment of a loan (often interest free, without any specific repayment terms and unlikely to be repaid) to an emp

In previous articles (for example, ‘The Rise and Fall of Christine Perrin’ in August 2014 and ‘La Peine Quotidienne’ in February 2015), I have considered HMRC’s relentless