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Nudge, Nudge, Say No More………or should you?

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 

Business Investment Relief

Business Investment Relief   Introduction   I decided to update this article as Business Investment Relief is something I have spoken to clients about quite a few times in recent 

Raymond Tooth – Discovery Assessment Invalid says Court of Appeal

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 

Staleness: HMRC Out of Time to Raise Discovery

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 

Careless & Deliberate Behaviour – Discovery Assessments

Understanding Careless or Deliberate Behaviour & Discovery Assessments As we have seen from the article setting out the requirements for a discovery assessment to be validly raised, a valid discovery 

How to Prevent a Discovery Assessment – the Facts

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 

When Can HMRC Make a Discovery Assessment?

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 

Discovery Assessment HMRC – Signpost

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 

EU Law & UK Tax

EU Law & UK Tax – A ‘High Level’ Analysis Introduction This note is a ‘high level’ analysis of the impact of EU law on the UK tax system and 

What is a Remittance?

What is a remittance? Non-UK domiciled individuals have the ability to claim the remittance basis which means that their overseas income or gains are not subject to UK tax if 


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