The PAC continued its inquiry over the role of HSBC’s private Swiss bank in facilitating tax avoidance and evasion with a heated two-hour hearing on Monday 9 March.
Michael Conlon QC (Hogan Lovells) examines the Court of Appeal decision in ITC, and the uncertainties that remain.
Permission to lodge late appeal
ECHR and double taxation
Process defects and appeals to the FTT
Witness summons and non-resident witnesses
While the much-anticipated decision in Project Blue is unsurprising, the decision raises some points of wider interest, including because HMRC prevailed by using FA 2003 s 75A, the SDLT anti-avoidance rule. Michael Thomas (Gray’s Inn Tax Chambers) reports
Ascertaining undeclared income
Inaccuracy penalties and inappropriate forms
Reliance on adviser and reasonable excuse