Error: Can't connect Warning: mysqli_query() expects parameter 1 to be mysqli, null given in /home/customer/www/hsfnotes.com/public_html/wp-content/themes/hsfnotes/template-parts/tpl_filters.php on line 186
Warning: mysqli_fetch_assoc() expects parameter 1 to be mysqli_result, null given in /home/customer/www/hsfnotes.com/public_html/wp-content/themes/hsfnotes/template-parts/tpl_filters.php on line 187
The UK government has today announced that the first reporting deadline under DAC 6 will be deferred for 6 months to allow taxpayers and advisors impacted by COVID-19 additional time to comply with their obligations. The first reports under DAC 6 will now be due by 31 January 2021. Read more
A Practice Direction issued by the President of the First-tier Tribunal (Tax) reminds taxpayers to consider whether it may be appropriate to engage with HMRC regarding the use of ADR.
Where a loss of tax has been brought about deliberately by a taxpayer, the time limit for HMRC to raise a discovery assessment is increased from 4 years to 20 years. In The Commissioners for HMRC v Raymond Tooth, the Court of Appeal held that for an inaccuracy to be "deliberate", there need not be any culpable conduct attributable to the taxpayer in question. Read more
In this webinar, we tackle some of the tricky issues relating to legal professional privilege that can arise in cross border and regulatory contexts, including tax investigations. Read more
HMRC are not entitled to compel taxpayers or third parties to provide information or documentation that is subject to legal professional privilege, whether in the context of an enquiry, investigation or litigation. In the context of corporate clients, the recent decision in the RBS Rights Issue Litigation [2016] EWHC 1017 (QB) has compounded uncertainty about what communications are privileged. This article considers that decision in detail. Read more
This article explains what should be done by a taxpayer faced with a request for information and documents after the conclusion of an investigation. Read more
This article considers the potential advantages of using ADR in tax disputes, how those ADR processes work, and how HMRC makes decisions relevant to the settlement of disputes by way of ADR. Read more
In light of the Commissioners' evidence to the Public Accounts Committee about the circumstances in which HMRC can resile from a settlement, this article considers what the law actually says on the matter. Read more