HMRC POWERS

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

The judgment in Tooth increases the weight of authority behind the issue of 'staleness', but that concept is not yet settled.

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.

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.

The international tax compliance landscape has become increasingly complicated and often unclear, as Ben Jones and Kunal Nathwani (Eversheds Sutherland) report.

Even staler.

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.