HMRC has published six consultation documents on implementing its strategy for ‘making tax digital’.
The Court of Appeal has handed down its judgment in the Prudential case, in what is hoped to be one of the final steps of this long lasting action between taxpayers invested in cross border portfolio holdings and HMRC. Simon Whitehead and Philippe Freund (Joseph Hage Aaronson), who acted for the taxpayers, summarise the outcome of this judgment and explain why it has taken so long.
As part of a package of measures, the Ministry of Justice (MoJ) is proposing to introduce a split-fee structure for the Tax Chamber of the First-tier Tribunal or the Upper Tribunal (Tax and Chancery). Nick Skerrett (Simmons & Simmons) comments on what's proposed.
Confiscation orders and discovery assessments
When is an application to reduce penalties because of ‘special circumstances’ a better bet than ‘reasonable excuse’? Peter Vaines (Squire Patton Boggs) considers a recent tribunal decision.
Retrospective legislation was lawful
Expert insight on one of the most powerful weapons in HMRC's arsenal
Reliance on accountant and reasonable excuse
Jurisdiction of the UT to hear appeals against information notices
HMRC is right to assert that the ‘no possibilities’ test should be applied immediately after the base loss period for losses from 1 April 2006, but wrong to apply it to periods before that date, writes Peter Cussons (PwC).