Tax Enquiry
Tax Conditionality – the tip of a titanic iceberg
They do say that nine-tenths of an iceberg sits below the surface of the water. The same may be true of some legislation, where all the consequences might not be immediately visible... Budget 2020 contains a mention of what looks...
The Loan Charge change – Reflections on a U-Turn
On the Friday afternoon before Christmas 2019, the government released the report by Sir Amyas Morse following his review of the Loan Charge legislation that had been introduced in 2016 and which had come into effect on 6/4/2019. The precise...
The Disappointment of Winning
Our firm recently won a case at the Tribunal or, to use the more formal language of the Courts, the Tribunal decided a case in favour of our client. You would think that we would be celebrating – but we...
HMRC information notices – are they validly issued?
Sch 36 FA 2008 provides HMRC with the power to issue Notices requiring a taxpayer or third party to provide documents or information and they are used in many tax enquiries. The rules regarding what can and cannot be sought...
Happy Birthday! Now report your employer!
The recent publication of a new list of employers who are being ‘Named and Shamed’ for failing to pay the National Minimum Wage does much to instil terror in the hearts of employers everywhere – but, if anything, it also...
Doomed to be misquoted?
Occasionally a Tax Case is published and, even at its first reading, the heart of the experienced tax investigations practitioner sinks as he realises that the case is likely to be misquoted by HMRC as supporting such-and-such a principle. For...
National Minimum Wage – First Employers ‘Named and Shamed’
On 8/6/14 the Government published details of the first 25 employers to be ‘named and shamed’ for failing to comply with the NMW legislation – but worse is likely to follow for future offenders. Proving the hours worked Traditionally HMRC,...