HMRC POWERS

It looks like any tax motivation is becoming fair game, writes Eloise Walker (Pinsent Masons).

Financial institution notices represent a greater power for HMRC, but this does not mean that tax managers’ hands are tied, write David Haworth and Rose Swaffield (Freshfields).

HMRC’s guidance is often of limited value in a taxpayer dispute, and there is an increasing trend of HMRC ‘clarifying’ guidance, sometimes with purported retrospective effect. What then is it good for, ask Sarah Ling and Jack Slater (Macfarlanes).

Tax authorities have access to more sources of information than ever before. Mark Whitehouse and Miranda Edwards (PwC) explore recent developments in HMRC’s international and domestic information powers and consider the implications for multinationals.

Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.

Clare Reeve Curatola and Kate Ison (Bryan Cave Leighton Paisner) provide practical insight on maximising the protection of legal professional privilege.

Adam Craggs and Michelle Sloane (RPC) explore the powers commonly deployed by HMRC during a criminal investigation.

Fiona McRobert, Assistant Director of HMRC’s ADR Team, explains how the department is ‘looking to embed a resolution mindset’.