Whether reasons for s 80 claim could be amended
James Bullock considers how effective the new ‘accelerated payments’ powers granted to HMRC will be in curbing tax avoidance schemes.
The Upper Tribunal has now handed down the eagerly awaited judgment in HMRC v Murray Group Holdings and others, better known as ‘the Rangers case’. Robert Waterson and Adam Craggs review the lessons from the decision, which resulted in a loss for HMRC in its campaign against EBTs that it is likely to appeal.
Interest ‘rolled over’ under a Ponzi scheme
Jurisdiction of the UT
According to the Financial Times (10 July 2014), lawyers are scrambling to file compensation claims against advisers who sold tax-saving schemes that have backfired to leave an estimated £5bn bill for individuals.
Legitimate expectation
Discovery assessment and HMRC’s knowledge
Penalties for late filing and posting
Obligation of HMRC to disclose employment records