COMPLIANCE

Although the Court of Appeal decided that HMRC had not made a discovery, the judgment contains unhelpful comments for taxpayers, as Clara Boyd and Ian Robotham (Pinsent Masons) explain.

Sabina Margulies (Lexis®PSL Tax) reviews lessons from the Court of Appeal judgment.

The Upper Tribunal upholds penalties for late filing even though no tax is due.

Despite little change in the primary law, HMRC's practice over its information powers is changing due to continued pressure to increase tax yield and demands for data from its international counterparts, as experts at Deloitte explain.

A lesson in procedural fairness.

Even staler.

The end to the Mansworth v Jelley affair.

Tori Magill (Good Cop9) examines the legal position concerning the balance between the right to privacy and the needs of HMRC to carry out its functions.

FA 2019 ss 80 and 81 insert into TMA 1970 and IHTA 1984 extended time limits for assessing income tax, CGT and inheritance tax (IHT), where a loss of tax arises out of, or involves, an offshore matter or offshore transfer....

FA 2019 Sch 4 introduces targeted rules to tax arrangements through which UK resident individuals (or in some cases companies) carrying on a business transfer a disproportionate part of their profits to offshore entities in low-tax jurisdictions and...