HMRC POWERS

In every enquiry into a business, HMRC will seek to subject the accounting records to data interrogation. Tony Monger (Mazars) explains what HMRC is looking for.

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

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.

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. 

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.

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.