Tooth nails the meaning of ‘Deliberate’ – and eradicates ‘Staleness’

The long-running saga of Raymond Tooth versus HMRC reached its conclusion in the Supreme Court recently when the Court dismissed the assessment that HMRC had made upon him. The case has been keenly followed by tax professionals through the First...

The Freedom of Information Act – A Right without Bite?

It’s nearly 20 years since the Freedom of Information Act 2000 (FOIA) was created. The Act was designed to create a public right of access to previously-inaccessible information held by public authorities but over the years concerns have been raised...

Deliberate penalties – what’s in a word?

As the public profile of tax compliance continues to grow, HMRC is increasingly under pressure to demonstrate that it is cracking down on tax evasion. This can be achieved through issuing larger numbers of penalties for the more serious failures...

Nudging HMRC to be more transparent with its nudge letters

In recent months, HMRC’s Risk and Intelligence Service (RIS) has once again issued “nudge” letters to individuals who HMRC believes have offshore income and gains that could be liable to UK tax. The “nudge” letters we have seen were issued...

More Bite From Tooth

Back in 2016, we wrote about the rather interesting case of Raymond Tooth V The Commissioners for HMRC (UKFTT723), in which HMRC had argued that Mr Tooth had acted in a deliberate manner by entering a correct figure in an...