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PENALTIES
Other cases that caught our eye: 8 November 2024
SDLT MDR was available:T Yeomans v HMRC [2024] UKFTT 955 (TC) (24 October) is another SDLT multiple dwellings relief case but unlike some other cases, where the phrase ‘clutching at straws’ comes to mind, this one was clearly...
Rebel without a causal link: HMRC’s position on proving carelessness
Sophie Rhind
Victoria Braid
Mainpay
should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
Private client review for September 2024
Damiano Sogaro
Edward Reed
Edward Reed and Damiano Sogaro (Macfarlanes) report on the latest on information notices, nudge letters, penalties and more.
P Cox and another v HMRC
Penalties for incorrect BADR claim upheld.
Another case that caught our eye: 28 June 2024
Procedure for assessing penalties:I Majid v HMRC [2024] UKFTT 491 (TC) (25 May) is what might be seen as a routine appeal against a penalty determination, but there is one point of general interest. An officer of HMRC had spoken to the...
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
Following a recent case, we can probably expect HMRC to be less flexible
on taxpayer requests for more time to comply with information notices,
writes Matthew Greene (Stewarts).
Full proof: more needed from HMRC to discharge their burden of proof
Sophie Rhind
It is encouraging to see the FTT dealing robustly with situations where HMRC
fail to discharge their burden of proof, writes Sophie Rhind (Macfarlanes).
Reforming tax dispute processes: HMRC’s call for evidence
Helen Adams
Helen Adams (BDO) offers some thoughts on the options and challenges posed by the potential reforms.
S Thompson v HMRC
Inaccuracies were careless but not deliberate.
K Pitt v HMRC
Upper Tribunal clarifies application of the follower notice regime.
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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
HMRC manual changes: 22 November 2024
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
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
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Apprenticeship Levy and Employment Allowance: new employer guidelines