Tax UK Notes

Whistleblowing on serious tax fraud and avoidance: what businesses need to know

When can a partial closure notice be required?

In Embiricos v HMRC [2022] EWCA Civ 3, the Court of Appeal confirmed that where HMRC's conclusion in respect of a matter enquired into has …

Kandore: information notices and the limits of open justice

HMRC's powers under Schedule 36 Finance Act 2008 ("Schedule 36") to obtain information relating to a taxpayer's affairs from a third …

Latest thinking from HMRC on offshore compliance

Within the framework of its "No Safe Havens" tax compliance strategy, HMRC has published two discussion papers concerning aspects of the …

SFO'S extra-territorial reach more limited than HMRC'S, at least for now

The Supreme Court has handed down judgment in the case of R (on the application of KBR, Inc) (Appellant) v Director of the Serious Fraud Office …

No litigation privilege in advice from accountants on tax structure

In a recent decision, the High Court has held that advice from accountants on a proposed new tax structure was not prepared for the dominant purpose of …

DAC 6 Reporting Deferred in the UK

The UK government has today announced that the first reporting deadline under DAC 6 will be deferred for 6 months to allow taxpayers and advisors …

HSF Trust Companies Survey - Tax Insights

We asked trust companies questions about the most significant risk and compliance issues they face. The survey mapped which specific tax compliance …

Rapid resolution of domicile disputes: be careful what you wish for

In Henkes v HMRC [2020] UKFTT 7645 (“Henkes”), the First-tier (Tax) Tribunal (“the Tribunal”) held that (a) …

The extra-territorial reach of HMRC's investigatory powers

In R (on the application of Jimenez) v the First-tier Tribunal (Tax Chamber) and HMRC  ("Jimenez"),1 the Court of Appeal determined that …

Limitation on who is a "Relevant Data Holder": a snoop too far?

Wilsons Solicitors LLP v HMRC ("the Wilsons case")1  is an interesting decision of the First-tier Tribunal (Tax Chamber) …

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 …