HMRC-ENQUIRIES

While awaiting the outcome of HMRC’s consultation on stamp tax modernisation, Richard Sultman and Peter North (Cleary Gottlieb) consider some missed opportunities and unresolved issues.

Nuel Oji

Stuart Walsh

Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.

Carrie Rutland

Helen Adams

Helen Adams and Carrie Rutland (BDO) provide a practical guide.

Sophie Rhind

Victoria Braid

Sophie Rhind and Victoria Braid (Macfarlanes) examine when the tribunal will exercise its power to direct HMRC to issue a closure notice in light of the recent case of Hitchins.

Carrie Rutland

Dawn Register

Carrie Rutland and Dawn Register (BDO) set out the most common reasons why claims can lead to an HMRC enquiry and they advise on how to reduce those risks.

Gideon Sanitt

Damiano Sogaro

Damiano Sogaro and Gideon Sanitt (Macfarlanes) review recent litigation on the tribunal's role in determining domicile issues when considering challenges to an enquiry or to information notices.

Richard Jeens

Tom Windsor

The recent tribunal decision in Credit Suisse Securities provides important guidance on when notice of enquiry is and is not given, as Richard Jeens and Tom Windsor (Slaughter and May) explain.

Mark Baycroft

Martin Mann

Martin Mann and Mark Baycroft (Markel Tax) reflect on the growing compliance burden and whether valuable reliefs will continue to be available in their current form.

Helen Adams

Recent decisions reinforce that HMRC is empowered to request information and investigate taxpayers’ positions without using statutory enquiry or information powers, writes Helen Adams (BDO).

Alexis Armitage

Adam Craggs

Adam Craggs and Alexis Armitage (RPC) consider the new proposed legislation, which will enable partial closure notices to be issued in respect of a discrete issue, while other issues remain under enquiry by HMRC.

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