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Supreme Court denies compound interest in taxpayer's claim against HMRC
In Littlewoods Ltd and others v HMRC [2017] UKSC 17, the Supreme Court delivered a controversial decision allowing HMRC's appeal, which means …
When can trustees assert privilege?
Recording: Originally broadcast: 31 October 2017 Faced with requests for disclosure (including from regulators and tax authorities) it can be a …
HMRC's Evasion and Avoidance Strategy: what you need to know
Recording: Originally broadcast Tuesday 5 September 2017 This webinar focussed on recent developments in relation to HMRC's …
Getting Justice in the Tribunal
This note is principally about two Supreme Court cases, R (on the application of UNISON) v Lord Chancellor [2017] UKSC 51 ("the fees case") and …
Privilege: to what is HMRC entitled?
HMRC are not entitled to compel taxpayers or third parties to provide information or documentation that is subject to legal professional privilege, …
The Limits of HMRC's Powers of Investigation
In support of HMRC's powers to enquire into and investigate taxpayers' affairs, Parliament has conferred upon HMRC powers to require taxpayers …
VAT and defined benefit schemes: taxing times ahead
It is more than three years since the European Court ("CJEU") rulings in Wheels and PPG, in which the CJEU found that (a) the supply of …
New UK criminal offences of failing to prevent facilitation of tax evasion
In our October 2016 briefing, we reported on the publication of the Criminal Finances Bill 2016–17. The Bill introduces a range of new measures to …
Alternatives to Litigation
HMRC is responsible for the collection and management of tax in the UK. It has a wide discretion in doing so, and in how it goes about litigating …
Do settlement agreements bind HMRC?
In the course of giving oral evidence to the Public Accounts Committee (the "PAC") in relation to the well-publicised settlement agreement …
Taxation of Restitution Interest Payments
The UK Government has introduced a new 45% tax charge on awards of restitution interest paid by HMRC to companies in relation to claims for tax paid …
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