COMPLIANCE

Zoe Andrews (Slaughter and May) takes a first look at the UK draft regulations implementing the EU's cross-border reporting rules.

We now have two recent opposing tribunal judgments on how the partial closure notice rules operate, writes Craig Thomson (Grant Thornton).

Barrister Michael Thomas (Pump Court Tax Chambers) believes there is a disturbing trend in our tax jurisprudence: an increasing number of important decisions made by HMRC are only capable of being challenged on a judicial review basis.

Recent court decisions suggest that the meaning of 'deliberate' behaviour now differs for ‘discovery’ assessments compared to penalties for errors, writes Helen Adams (BDO).

Hyrax and Curzon Capital Ltd consider for the first time the provisions governing HMRC’s ability to seek an order that a scheme is notifiable under DOTAS. Lee Ellis and Cristiana Bulbuc (Stewarts Law) consider the practical implications.

Investigations are taking longer, but HMRC’s new facility offers multinationals the prospect of quicker resolution for certain disputes.

Barrister Patrick Cannon (15 Old Square) provides first hand insight on when and how to use mediation to resolve tax disputes.

Adam Craggs and Constantine Christofi (RPC) consider the recent spate of IR35 cases that have been considered by the First-tier Tribunal, HMRC's increasing use of 'jeopardy amendments' and the increasing number of judicial review challenges being brought against HMRC.  

Is it possible that this unhappy episode could be coming to a conclusion?