Tax investigations

VAT Invigilations - When best judgement isn’t even good Anyone who has only been involved with tax since 2005 might not be aware that prior to that point, rather than there being one HM Revenue and Customs, there had been...

How hard is it to pay tax?

You would think it should be very easy to pay money to HMRC. After all, as we are being regularly reminded, it is the very raison d’etre for its existence. It is the channel for funds to the Treasury and...

‘Twas the afternoon before Christmas

If such a thing even exists, the Friday afternoon before the Christmas Break is rarely an exciting or memorable occasion in the tax world. Not like 31 January, say, or the morning before the Budget announcement, when minds are sharp...

Follower Notice unlawfully issued

Mazars on behalf of their client G Haworth have successfully persuaded the Court of Appeal that HMRC unlawfully issued a Follower Notice to their client (Link). We will shortly also be publishing a case note highlighting the legal and technical...

Statutory Review into ‘unfair’ Loan Charge

The Loan Charge, as part of the 2017 Finance Act (No. 2), was introduced by the Treasury to recover unpaid taxes by individuals who have used ‘disguised remuneration’ schemes - a complex form of tax avoidance involving contractors, employees or...

The benefits of an Independent Review by HMRC

The Taxes Acts allow taxpayers to ask for an independent review of an appealable decision by HMRC. The review is carried out by an independent officer within HMRC’s Appeals and Reviews teams. However, recent evidence suggests that many taxpayers remain...

Tribunals prove their worth

At a time when HMRC is actively seeking to remove the Tribunals from approving of third party information notices, there have been a number of cases which show the importance of why the Tribunals should still be involved in the...

Disguised remuneration – an update

We reported earlier this year on how to take advantage of the final opportunity in settling any liabilities arising from various forms of historic tax planning which HM Revenue and Customs (HMRC) badges under the disguised remuneration banner. We also...

HMRC ramps up pressure on EBTs

The expectation that HMRC would use the Supreme Court’s decision in the Rangers Case as the basis of issuing Follower Notices and Accelerated Payment Notices has now become a reality.  As set out in our previous blog HMRC is required...

2019 Loan Charge – another weapon for HMRC

If you have used remuneration tax planning involving loans (after 6 April 1999) and choose not to settle with HMRC using the current disguised remuneration settlement opportunity, then any outstanding loans as at 5 April 2019 will be subject to...

Settling disguised remuneration arrangements

In August last year we reported on the announcement of HMRC’s final settlement opportunity for Employee Benefit Trust (EBT) users as a result of the infamous Rangers decision in the Supreme Court. This settlement opportunity is also for Employer Financed...

Requirement to Correct – Don’t ignore it!

In yet another attempt to persuade people with offshore assets to come forward, and settle any outstanding tax liabilities, HM Revenue & Customs (HMRC) has another round of new legislation in its armoury. The second 2017 Finance Act introduced extremely...

The Future without Future

Investors in Future Capital Partners (“FCP”) investments will most likely have seen or been advised by FCP itself that the company may shortly go into liquidation or administration. This has been reported in various newspapers, including the Financial Times. Participants...

Rangers and Follower Notices – Key Dates

Following the Supreme Court’s decision in the Rangers Football Club Employee Benefit Trust (“EBT”) case last year. HMRC is sending Follower Notices to companies with EBTs, users of Employer Financed Retirement Benefit Schemes (EFRBS) and other (what HMRC terms) similar...

Paradise Islands are no longer heavenly………………

As reported in our previous blog the International Consortium of Investigative Journalists (ICIJ) continues its ongoing campaign to shed the opaque veil that masks offshore financial centres. The ICIJ has received nearly 13.4 million documents from a combination of leaked files...

When the taxman came to Albert Square

Thursday’s 26 October 2017 episode of EastEnders showed that loveable rogue Billy Mitchell was the subject of a HMRC compliance visit. Many of the businesses on the show are portrayed as family owned and managed and Billy is a Partner...

Bermuda Books – the new Panama Papers?

On 25 October 2017 news broke that there has been a ”huge leak” of personal information from major offshore law firm Appleby. The firm stated they were in the process of warning clients that may be implicated as a result...

Tax avoidance – down for the count?

Has HM Revenue & Customs (HMRC) got tax avoiders down and out for the count? In another round of litigation, HMRC have soundly defeated two film partnerships (Samarkand Film Partnership No.3 and Proteus Film Partnership No.1) in the Court of...

PAC reports HMRC must try harder, again!

The Public Accounts Committee (PAC) in its report of 15 April 2016 is critical of HMRC’s approach to addressing tax evasion which includes concerns over its criminal prosecution policy. To be fair to HMRC, it is not possible to undertake...