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What is the state of play with HMRC’s so called? “nudge letters” As HMRC gathers it’s thoughts on how to narrow the tax gap and recover monies used to assist 
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With most employers thoughts now turning to Rishi Sunak’s replacement for the Coronavirus Job Retention Scheme, or furlough scheme as it is more widely known, the ‘old’ scheme cannot yet 
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CDP Corporate & SDLT – HMRC Letters – Background We have been involved with a number of clients, over several years, who have received letters from HMRC relating to their 
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Raymond Tooth – Discovery Assessment is Invalid says Court of Appeal Background – Tooth v. HMRC In the case of Raymond Tooth v HMRC, Mr Tooth had participated in a 
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Staleness: When HMRC is Out of Time to Raise Discovery What is staleness? Firstly, it should be stated that this is very much a developing area of the law. As 
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General – How to Prevent a Discovery Assessment One of the requirements for their to be a discovery, absent any careless or deliberate behaviour by the taxpayer or agent, is 
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Change of View… When HMRC Launches a Discovery Assessment In order for them to make a discovery, it must be as a result of HMRC coming to a new conclusion 
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Discovery assessment HMRC – signpost   Introduction   Welcome to our Signpost relating to HMRC discovery assessments. This provides a link to a number of articles we have put together 
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Code of Practice 9 (“COP9”) – Signpost   HMRC COP 9 cases Code of Practice 9 is only issued as part of the Contractual Disclosure Facility and is solely used by HMRC 
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COP9 investigation process What is COP9? Code of Practice 9 (“COP9”) is a document that is issued by HMRC. It is part of its Contractual Disclosure Facility or CDF. COP9 is 
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