HMRC-ENQUIRIES

Edward Reed and Emma Critchley (Macfarlanes) recap the key private clients announcements in the Spring Budget, and they report some interesting procedural points when challenging HMRC enquiries.

HMRC’s retention and internal sharing of copy documents obtained during criminal investigation.

Upper Tribunal dismisses challenges to accelerated payment notices.

Goodwill: M Smith and another v HMRC [2023] UKFTT 912 (TC) (30 October 2023) is an interesting case on the nature of goodwill. Two individual IFAs operated via a company. The business of the company was transferred to an LLP and the capital accounts...