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HMRC-ENQUIRIES


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 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.

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.

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.

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.
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).

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.

Helen Adams and Lisa Vanderheide (BDO) set out what to do in the event of HMRC notifying a client of its intention to carry out a compliance check using ‘cross-tax working’.

Isobel Clift answers a query on HMRC information powers and close company enquiries

Cathya Djanogly reviews the decision of the High Court in Privacy International on whether HMRC should have disclosed information about an investigation it was carrying out.

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