Gideon Sanitt (Macfarlanes) considers the decision in Ingenious Media and when HMRC may be excused from its duty of confidentiality.
David Pickstone (Stewarts Law) reviews the recent Upper Tribunal decision in Ingenious, which considered whether HMRC could make allegations of dishonesty at a late stage in proceedings without having pleaded them in its statement of case.
The Treasury has published its proposed next steps on tackling evasion and avoidance. James Bullock (Pinsent Masons) reviews the detail.
Tax-geared penalties
OUR PICK OF THIS WEEK'S CASES
Setting off losses on a trade succession
Michael Conlon QC (Hogan Lovells) examines the Court of Appeal decision in ITC, and the uncertainties that remain.
Criticism of HMRC’s failure to prosecute HSBC Swiss tax evaders has been quite unfair, writes Jonathan Fisher QC (Devereux Chambers). There are problems with criminal prosecution and the decision to focus on tax collection through civil settlement is the right one. It makes little sense to criminally prosecute these cases.
Following the censure HMRC received over the HSBC ‘Swiss leaks’ before the Public Accounts Committee on 11 February, as well as further press criticism, HMRC issued a statement on when and how it came by the leaked HSBC Suis
The Swiss arm of British bank HSBC has been accused of helping its wealthy clients with offshore tax avoidance – and even tax evasion – in the national and international press.
Jennie Granger (HMRC) writes about the new approach of HMRC’s enforcement and compliance business.