Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
HMRC has extensive powers to require information and documentation from taxpayers. These powers were bolstered in the last Finance Act to include financial institution notices. Failure to comply with information notices can attract penalties. The most severe penalties are those imposed by the Upper Tribunal. In this quarterly review we examine HMRC’s increasing use of these powers together with HMRC’s penchant for ‘nudge’ letters and recent developments in the application of the transfer of assets abroad provisions.
Tax geared penalties imposed by the Upper Tribunal
FA 2008 Sch 38 para 1 provides the power for an officer of HMRC to require a taxpayer to provide information or produce documents if they are ‘reasonably required’ for the purpose of ‘checking the taxpayer’s tax position’. Paragraph 7 of Sch 36 sets out...
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Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
HMRC has extensive powers to require information and documentation from taxpayers. These powers were bolstered in the last Finance Act to include financial institution notices. Failure to comply with information notices can attract penalties. The most severe penalties are those imposed by the Upper Tribunal. In this quarterly review we examine HMRC’s increasing use of these powers together with HMRC’s penchant for ‘nudge’ letters and recent developments in the application of the transfer of assets abroad provisions.
Tax geared penalties imposed by the Upper Tribunal
FA 2008 Sch 38 para 1 provides the power for an officer of HMRC to require a taxpayer to provide information or produce documents if they are ‘reasonably required’ for the purpose of ‘checking the taxpayer’s tax position’. Paragraph 7 of Sch 36 sets out...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
