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INVESTIGATIONS


The decision in Bilta has clarified the scope of privilege in internal investigations undertaken in the context of HMRC enquiries, write Kate Ison and Clare Reeve (Berwin Leighton Paisner).
 
HMRC needs to exercise more care when applying for search and seizure warrants, writes Patrick Cannon (15 Old Square Tax Chambers).
 
Large companies should refresh their raids and critical incident procedures in the event that HMRC decides to investigate, writes Jason Collins (Pinsent Masons).
 

Richard Jeens (Slaughter and May) considers the additional pressures on tax authorities to tackle evasion and avoidance, and how this promises not only more, but more intense tax enquiries and litigation for taxpayers; as well as identifying new tools added to HMRC’s repertoire, such as the new partial closure notice provisions.

The report published last month contains some fascinating detail which throws a light on how HMRC is approaching the task of settling large disputes, writes Chris Davidson CBE (KPMG).
 
Corporates are facing the regulatory scrutiny once reserved for banks. Gideon Sanitt (Macfarlanes) considers the treatment of the costs of such investigations.
 

A review letter from HMRC cancels discovery assessment, writes Nicole Kostic (RPC).

Paul McGrath and Robert Posgate (Withers) explain the reporting requirements and responsibilities of the register of people with significant control, which comes into effect from 6 April 2016.

Tori Magill and Anne-Marie Ottaway (Pinsent Masons) look at the recent controversy and the fine lines between tax planning, avoidance and evasion.

Expect HMRC to act, writes Jessica Parker (Corker Binning)

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