HMRC-GUIDANCE

Reasonable excuse and reliance on third party: In Xcel Consult Ltd v HMRC [2025] UKFTT 96 (TC) (30 January), the taxpayer was arguing that she had a reasonable excuse defence in her appeal against a VAT surcharge because she had relied on her...

Gerald Montagu

Elmira Jazottes

Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.

Jo Crookshank

Gary Barnett

HMRC have set out their expectations for taxpayer VAT compliance processes and procedures. This and other recent developments in VAT are examined by Jo Crookshank and Gary Barnett (Simmons & Simmons).

Abigail McGregor

Steven Porter

Steven Porter and Abigail McGregor (Pinsent Masons) consider the UTT regime after two years of operation.

Jack Slater

Sarah Ling

HMRC’s guidance is often of limited value in a taxpayer dispute, and there is an increasing trend of HMRC ‘clarifying’ guidance, sometimes with purported retrospective effect. What then is it good for, ask Sarah Ling and Jack Slater (Macfarlanes).

Will Timbrell

Kyra Motley

There is no equivalent to a Foundation registered with the Dubai International Finance Centre Registrar of Companies under English law. How then should they be treated for UK tax purposes? Kyra Motley and Will Timbrell (Boodle Hatfield) investigate.

Joshua Stevens

Brigitte Potts

Brigitte Potts (Evelyn Partners) and Joshua Stevens (Pump Court Tax Chambers) consider the VAT implications of credits or biodiversity units in tackling climate change.

Sebastian Prichard Jones

Andrew Crozier

HMRC’s updated guidance on the treatment of profits arising within, and distributions from, US LLCs is unsatisfactory in a number of respects, write Sebastian Prichard Jones and Andrew Crozier (Macfarlanes).

Zoe Andrews

Mike Lane

Consultation responses to the VAT treatment of fund management services, Euromoney on the purpose test, recent developments on Pillar Two, and a report on the tax contribution of the UK banking sector are examined by Mike Lane and Zoe Andrews (Slaughter and May).

Zoe Andrews

Mike Lane

Target Group, Vermilion and changes to HMRC’s guidance on the double tax treaty passport scheme are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).

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