‘taxing statutes draw their life-blood from real world transactions with real world economic effects’ In 1936, Lord Tomlin made the (now) infamous statement which gave tax payers a decisive advantage over HMRC. In effect, this was an approval for tax professionals to exercise their ingenuity in the pursuance of a 
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Tax policy: What did the recent party conferences tell us about tax? Despite the frequency of the polls appearing in British media, the only test of opinion which really matters is the General Election. Nevertheless, all the major political parties recognise the merit in keeping the country on their side 
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April 2019 loan charge: HMRC’s curious intervention on EDM1239 For those of you who: • bought a newspaper on Saturday; • that newspaper was The Times; and • you managed to get to the outer most limits of the Money section then you might have seen I was quoted in 
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Employed or not: Is HMRC wrong on IR35 determination? Since the turn of the century, the UK’s tax code has grown into one of the largest in the world. Yet it’s not so comprehensive that it can overcome all of the issues which confront HMRC. One notable headache has been 
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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 
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Mind the tax gap Introduction – tax gap Jostling for attention with the start of the World Cup was the publication of HMRC’s report on the tax gap. Indeed, this report might have made better viewing for Saudi Arabia fans who were walloped by the hosts (if the Russians can 
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Introduction: Tax avoidance and weaponisation If you ask the man on the street the following questions: Does HMRC have sufficient powers to crackdown on tax avoidance? Has HMRC been successful in reducing tax avoidance? then the answer is likely to be ‘no’ to both. However, the answer is, by any 
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Codes of Practice (“COP”) 8 and 9 Background HMRC’s Fraud Investigation Service undertakes the most serious tax investigations. Its investigations will under COP9 or COP 8. COP 9 HMRC undertakes investigations under COP9 where they suspect fraud. It is a highly prescribed code of conduct setting out how HMRC will 
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2019 Loan Charge and Parliament: Retro-spectacle The question of whether something might be fair or not is usually highly subjective. There is, of course, an old cliché suggesting that anything’s permissible in romance and military conflict but we all know that’s not strictly true. In those situations as with many 
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Yesterday we heard an announcement which could spell the decline of the BOTS. That’s the British Overseas Territories, rather than our mechanoid friends. For example, the list of British Overseas Territories (“BOTS”) would include jurisdictions such as the British Virgin Islands (BVI), Bermuda, Gibraltar and the Cayman Islands. It should 
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