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Taxpayer Rights & Rule of Law

Private Sector IR35 & Off Payroll Working – Tax & April 2020

IR35 & THE PRIVATE SECTOR It has been announced that the IR35 provisions relating to the public sector will be introduced into the private sector. The proposal is subject to consultation and the precise details are unclear, however, it might be useful to look at the public sector provisions to 

Professional Negligence & Tax Advice

In recent years, HMRC has made no secret of its stepping up efforts to increase the amount of tax revenue which it generates. The latest edition of its annual report, published in July, underlined its determination to “bear down on avoidance and evasion”. Its success in doing so can be 

Tax Disputes with HMRC

Tax Disputes with HMRC In this article we take a look at how to progress matters when discussions with the inspector appear to have broken down or reached an impasse. Where agreement just cannot be reached between the taxpayer and HMRC the final outcome is the Tax Tribunal. However, the 

IHT and DOTAS: Inheritance Tax & Disclosure of Tax Avoidance Schemes

IHT and DOTAS HMRC recently introduced a new “hallmark” to the Disclosure of Tax Avoidance Schemes (DoTAS) regime with a view to closing the inheritance tax avoidance gap. The scope of the new hallmark is very wide, and consequently any inheritance tax planning should be carefully considered in light of 

Judicial Review and tax

Judicial Review and tax Introduction – Judicial review and tax The 2019 Loan Charge Action Group has launched a judicial review against HMRC in relation to the 2019 Loan Charge. In recent years, the courts have seen a sharp increase in judicial review against HMRC. In light of this, I 

Amending HMRC’s Civil Information Powers

HMRC seeks power to force disclosure of third party information without judicial oversight HMRC has opened a consultation “Amending HMRC’s Civil Information Powers”. According to HMRC, the ‘massive change’ in the information systems landscape since its current powers to demand third-party information were originally legislated, suggest that they may no 

HMRC’s Latest Guidance on the Requirement To Correct (RTC)

Extra time before penalties? No it’s not the World Cup, it’s HMRC’s latest guidance on the Requirement To Correct (RTC). The Requirement to Correct was introduced in Finance (No 2) Act 2017 and required taxpayers to correct historic UK tax issues in respect of offshore income, assets and activities. If 

April 2019 loan charge – ‘If you tolerate this….

April 2019 loan charge – ‘If you tolerate this… …your children will be next’ sang the Manic Street Preachers almost a decade ago. I don’t think they were singing about the April 2019 loan charge. It is quite possible they were not talking about tax at all. It’s not a 

Tax News; HMRC is Targeting Expats Living Abroad

Is HMRC targeting expats? According to The Telegraph, HMRC made 1,006 requests to foreign revenue authorities in 2017 for assistance with the recovery of tax debt. The figures, obtained under a Freedom of Information request, show that these requests resulted in the recovery of £5.7m of tax, an almost threefold 

The tax name and shame game

Tax name and shame game In his 19th-century heyday, Phineas T Barnum was renowned as a showman, promoter, serial entrepreneur and even a politician. Even though he died more than a century ago, his fame endures, thanks in no small part to a successful West End musical and recent Hollywood