COMPLIANCE

Sarah Squires (Old Square Tax Chambers) reviews the operation of the loss restriction, the deductions allowance and the related compliance issues.

David Whiscombe

In yet another IR35 case, a tribunal considers the procedural validity of the determinations under which HMRC sought to collect the tax.

Keith Gordon

The loan charge has driven a coach and horses through the statutory safeguards, writes barrister Keith Gordon (Temple Tax Chambers).

Helen Adams

Recent decisions reinforce that HMRC is empowered to request information and investigate taxpayers’ positions without using statutory enquiry or information powers, writes Helen Adams (BDO).

Despite the review being an important event, it appears to be very much business as usual at HMRC.

Paul Aplin OBE

Paul Aplin OBE (A C Mole & Sons) welcomes proposals for a new professional standards committee.

Gideon Sanitt

Gideon Sanitt (Macfarlanes) examines the decision in Ingenious that provides some guidance as to how courts might determine whether there is a genuine commercial trading arrangement with a view to profit.

The UK has published draft regulations adopting an EU directive that promises faster resolution of double taxation disputes between member states.

Adam Craggs

Michelle Sloane

In this quarterly review, Adam Craggs and Michelle Sloane (RPC) consider HMRC’s increasing propensity to seek the production of documents from accountants and other professional advisers, HMRC’s new policy of challenging taxpayers’ loan relationships, and the increase in the number of domicile enquiries launched by HMRC.