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HMRC powers
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HMRC-POWERS
Seeing the broader picture: HMRC’s information exchange powers and obligations
Mark Whitehouse
Miranda Edwards
Tax authorities have access to more sources of information than ever before. Mark Whitehouse and Miranda Edwards (PwC) explore recent developments in HMRC’s international and domestic information powers and consider the implications for multinationals.
Fishing and fishy? HMRC third party interviews in employment tax investigations
Christopher Kientzler
Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.
How to handle transfer pricing discovery assessments
Joel Cooper
Paula Ruffell
Joel Cooper and Paula Ruffell (EY) outline the steps to consider if a
‘protective’ discovery assessment is issued for a transfer pricing matter.
Private client review for April 2023
Hannah Kalveks
Edward Reed
SDLT mixed use rates, procedural issues, taxpayer confidentiality and HMRC
‘fishing expeditions’ are among the topics reviewed by Edward Reed and
Hannah Kalveks (Macfarlanes).
Hoey: you’d better PAYE up
Hugh Gunson
Guy Bud
Hugh Gunson and Guy Bud (Charles Russell Speechlys) examine the Court of Appeal’s decision which has potentially far-reaching consequences for the PAYE system.
20 questions: HMRC’s civil and criminal powers
Constantine Christofi
Adam Craggs
A detailed guide by Adam Craggs and Constantine Christofi (RPC).
Private client review for November 2021
Georgia Rawlinson
Edward Reed
Edward Reed and Georgia Rawlinson (Macfarlanes) provide this month’s review of developments affecting private clients.
HMRC’s updated SAO guidance: a focus on the main duty
Laura Harper BDO
Jason Land
Jason Land and Laura Harper (BDO) examine HMRC’s updated guidance on
SAO qualifying businesses.
Embiricos and the future of partial closure notices
Catrin Harrison
Hugh Gunson
Dominic Lawrance
Catrin Harrison, Dominic Lawrance and Hugh Gunson (Charles Russell Speechlys)
examine an Upper Tribunal decision that is disappointing for taxpayers and
removes a strategic weapon for anyone faced with a domicile enquiry.
Litigation privilege and structuring advice
Dominic Stuttaford
Tax structuring advice received and implemented, even where there is a
perceived risk of challenge, will not benefit from litigation privilege, writes
Dominic Stuttaford (Norton Rose Fulbright).
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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
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
Reporting of offshore interest
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
Apprenticeship Levy and Employment Allowance: new employer guidelines
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC