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Contentious tax: quarterly review

Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).

CRS and HMRC nudge letters

Since early 2017 HMRC has issued nudge letters to taxpayers to encourage taxpayers to act in a certain way. This type of HMRC activity is driven not by statute but by behavioural science. A batch of nudge letters were recently issued by HMRC to a large number of individuals who may have overseas income and/or gains and whose tax affairs it suspects may not be fully in order and up to date.

Revenue authorities globally are making more use of information obtained under the CRS and other exchange of information arrangements with tax authorities of other jurisdictions. HMRC has had information exchange agreements in place with certain of the UK’s crown dependencies since 2014 and has been able to request material under other information exchange provisions (notably...

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