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Deliberate behaviour
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Deliberate behaviour
DELIBERATE-BEHAVIOUR
A Outram and another v HMRC
UT overturns FTT finding of deliberate behaviour as error of law.
Private client review for April 2024
Sam Epstein
Edward Reed
Recent decisions on mixed use SDLT, taxpayer behaviour and the meaning of
‘service’ under the remittance basis rules are reviewed by Edward Reed and
Sam Epstein (Macfarlanes).
Full proof: more needed from HMRC to discharge their burden of proof
Sophie Rhind
It is encouraging to see the FTT dealing robustly with situations where HMRC
fail to discharge their burden of proof, writes Sophie Rhind (Macfarlanes).
Deliberate behaviour: what you need to know
Sophie Rhind
Is it true that what you don’t know can’t hurt you? Sophie Rhind
(Macfarlanes) examines recent cases considering the level of knowledge
sufficient for a finding that a taxpayer’s behaviour is ‘deliberate’.
Couldn’t careless? Reasonable care and the role of professional advisers
Constantine Christofi
Adam Craggs
Whilst taking professional advice will usually mean a taxpayer has taken
reasonable care, not taking advice does not necessarily mean a taxpayer has
been careless, write Adam Craggs and Constantine Christofi (RPC).
When careful taxpayers make mistakes
Claire Miles
If a lack of reasonable care is being alleged, it is essential to understand the taxpayer’s mindset when the mistake was made, as well as any steps the taxpayer took to file their return correctly, writes Claire Miles (Willkie Farr & Gallagher).
Discovery following Tooth: what should advisers do now?
Helen Adams
Helen Adams (BDO) considers the ways the Supreme Court decision will change advisers’ approach to discovery appeals.
Discovery assessments: the Supreme Court’s decision in Tooth
Ian Robotham
Clara Boyd
Clara Boyd and Ian Robotham (Pinsent Masons) examine the unanimous decision that clarifies the law in relation to discovery assessments.
Cliff edge: the meaning of ‘deliberate’
Constantine Christofi
Sam Brodsky
A recent tribunal decision erodes the behavioural distinction between ‘careless’ and ‘deliberate behaviour’, write Constantine Christofi (RPC) and Sam Brodsky (Gray’s Inn Tax Chambers).
Private client review for October 2019
Andrew Goldstone
Stuart Adams
Andrew Goldstone and Stuart Adams (Mishcon de Reya) review the latest tax developments affecting private clients.
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
HMRC manual changes: 1 November 2024
Chancellor targets businesses with CGT and IHT reforms
Spotlight on LLPs and disguised remuneration arrangements
New HMRC guidance for taxpayers on rental income
Land transaction tax in Wales: relief for special tax sites
CASES
Read all
GCH Corporation Ltd and others v HMRC
Abbeyford Caravan Company (Scotland) Ltd v HMRC
S Lefort v HMRC
Other cases that caught our eye: 1 November 2024
R (oao Rettig Heating Group UK Ltd (in liquidation)) v HMRC
IN BRIEF
Read all
Autumn Budget 2024: a tax hike with familiar terrain
Autumn Budget 2024: tax on corporates
Autumn Budget 2024: private equity reforms - a mixed bag
Autumn Budget 2024: non-doms - the end of an era
Autumn Budget 2024: nothing too scary about CGT
MOST READ
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‘Arrangements’ that disqualify new EMI option grants
A tale from the frontline of SDLT
Pillar Two and funds: there is no panacea
One minute with... Paul Rosser
Government to consult on new corporate re-domiciliation regime