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Thinking - Blog
Leaving customers without signal: the task of re-building the Telecoms Code
Now almost 30 years old, the Electronic Communications Code (the 'Code'), falls far short of representing the needs of a swiftly developing communications network.
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Thinking - Blog
H&M: Brave New World?
We have all been involved in lease negotiations where there are differences of opinion as to what is or is not institutionally acceptable.
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Thinking - Blog
End of the line for Village Greens?
Nothing can be more frustrating for a developer to see its scheme delayed or worse still derailed by an application for the registration of land as a town or village green ("TVG").
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Thinking - Blog
Rights of Light
Rights of light are an easement and are commonly acquired simply by a neighbour having enjoyed the light over a neighbouring building owner’s land for a period of 20 years without interruption.
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Thinking - Blog
HMRC’s enquiry and correction powers
A key consultation on proposed reforms to HMRC’s enquiry and correction powers closed today. Dubbed the "Tax Administration Framework Review – New Ways to Tackle Compliance", this consultation is the latest in a series aimed at streamlining the UK’s tax system. The goal? To make it easier for taxpayers while enabling HMRC to allocate resources more effectively.
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Thinking - Blog
Upper Tribunal considers when a dividend becomes 'due and payable' for tax purposes
In HMRC v Gould [2024] UKUT 00285 (TCC), the Upper Tribunal dismissed HMRC's appeal and confirmed that an enforceable debt arises when a company pays an interim dividend to one shareholder but not another of the same class.
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Thinking - Blog
HMRC launches new R&D voluntary disclosure platform amid increased enforcement and compliance efforts
HMRC has introduced a new specialist research and development (R&D) voluntary disclosure platform. This development follows a surge in HMRC R&D compliance activity, including a number of high-profile raids and arrests. It is estimated that over £1 billion has been lost to the Exchequer in recent years due to speculative or fraudulent R&D claims, prompting HMRC to take decisive action.
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Thinking - Blog
Loan Charge regime - High Court strikes out taxpayers' Part 8 claims as abuse of process
In allowing HMRC's appeal, the High Court determined that the taxpayers' claims in respect of the Loan Charge should be struck out as an abuse of process.
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Thinking - Blog
Upper Tribunal allows taxpayers' appeals on 'deliberate' behaviour
In the Outram case, the Upper Tribunal overturned the First-tier Tribunal's decision concluding that it had erred in law when deciding that the taxpayers had deliberately filed an inaccurate return without considering the subjective knowledge and intention of the taxpayers concerned.
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Thinking - Blog
Will the UK government's latest measures targeting promoters of tax avoidance and fraud be effective?
In this article, which is based on an article published in Issue 4 2024 of the British Tax Review, Adam Craggs considers whether the UK's latest measures targeting promoters of tax avoidance schemes and tax fraud will be effective.
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Thinking - Blog
Preparing for an HMRC dawn raid
How to prepare for a dawn raid by HMRC under the authority of a search warrant issued under the Police and Criminal Evidence Act 1984 (PACE), enabling them to enter and search premises to investigate suspected tax fraud.
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Thinking - Podcast
Taxing Matters: Deck the halls… with weird and wonderful taxes throughout history
In our special Christmas episode, Alexis Armitage, RPC's Taxing Matters podcast host and Senior Associate in our Tax Disputes and Investigations team, is joined by Andrew Hubbard, editor-in-chief of Tolley's Taxation Magazine. From candles to beards, join them as they discuss the most bizarre taxes that have existed throughout British history.
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Thinking - Blog
Tribunal strikes out HMRC's application for a tax-related information notice penalty against Paul Baxendale-Walker
In Paul Baxendale-Walker v HMRC [2024] UKUT 00154 (TC), the Upper Tribunal granted an application by the taxpayer, under Rule 8(3)(c) of the Upper Tribunal Procedure (Upper Tribunal) Rules 2008, to strike out HMRC's application seeking a tax-related information notice penalty pursuant to paragraph 50 of Schedule 36, Finance Act 2008.
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Thinking - Publication
Tax Bites – December 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
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Thinking - Blog
Court of Appeal considers HMRC's CIS powers and allows taxpayers' appeals
In Beech Developments (Manchester) Ltd & Ors v Commissioners for His Majesty's Revenue and Customs [2024] EWCA Civ 486, the Court of Appeal allowed the taxpayers' appeals, finding that HMRC does have power to issue a direction under Regulation 9(4) of the Construction Industry Scheme Regulations, where the same amount has been subject to a regulation 13 determination.
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Thinking - Podcast
Taxing Matters: ADR in tax disputes with HMRC's ADR lead, Fiona McRobert
In this month's episode of Taxing Matters, Alexis Armitage is joined by HMRC's Alternative Dispute Resolution (ADR) lead, Fiona McRobert, to discuss HMRC's approach to the ADR process, and how tax disputes may be resolved outside the Tax Tribunals and the court system.
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Thinking - Publication
V@ update - November 2024
Welcome to the November 2024 edition of RPC's V@, a monthly update which provides news and analysis from the VAT world.
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Thinking - Publication
Customs and excise quarterly update - November 2024
Welcome to the November 2024 edition of RPC's Customs and Excise Quarterly Update.
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Thinking - Blog
Tribunal finds insufficiency in taxpayer's return was not brought about "deliberately"
In allowing the taxpayer's appeal, the First-tier Tribunal determined that an insufficiency in his return was not brought about deliberately.
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Thinking - Publication
How to prepare for an HMRC dawn raid
One of the most stressful moments for a business is HMRC officers demanding access to your premises, so it is vital to have plans in place in the event of a dawn raid.
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Thinking - Blog
Contentious Tax Quarterly Review: November 2024
Adam Craggs and Harry Smith of RPC provide a Contentious Tax Quarterly Update discussing recent developments in tax litigation.
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Thinking - Blog
Tribunal finds that mixed-use SDLT rates should be reined in for purchase of property and paddock
The Upper Tribunal dismissed HMRC's appeal and confirmed that mixed stamp duty land tax (SDLT) rates applied to the purchase of a property and adjoining paddock where a grazing lease for the latter was granted shortly after completion.
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Thinking - Publication
Tax Bites – November 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
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Thinking - Blog
Autumn Budget 2024: summary of implications for businesses and individuals
Adam Craggs explores the key implications of the Autumn Budget 2024 for businesses and individuals.
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Thinking - Blog
Tribunal allows taxpayer's appeal against information notice
In Sangha v HMRC [2024] UKFTT 00564 (TC), the First-tier Tribunal (FTT) allowed, in part, Mr Sangha's appeal against HMRC's information notice issued under paragraph 1, Schedule 36, Finance Act 2008 as the information was not 'reasonably required' or in his 'possession or power'.
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Thinking - Publication
V@ update - October 2024
Welcome to the October 2024 edition of RPC's V@, a monthly update which provides news and analysis from the VAT world.
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Thinking - Blog
HMRC's DOTAS application struck out
In HMRC v Elite Management Consultancy Ltd (in administration) and Adam Bale [2024] UKFTT 00567 (TC), the First-tier Tribunal (FTT) confirmed that HMRC's DOTAS application was automatically struck out when it failed to serve an authorities bundle on time in breach of an 'unless' order issued by the FTT.
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Thinking - Podcast
Taxing Matters: Crystal ball gazing with Jasprit Singh
In this episode, Alexis Armitage, RPC's Taxing Matters podcast host and Senior Associate in our Tax Disputes and Investigations team, is joined by colleague and fellow Senior Associate, Jasprit Singh. Join them as they gaze into their crystal ball and predict what could be on the horizon for taxpayers under the new Labour government.
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Thinking - Blog
Tribunal confirms that trading had commenced for the purposes of Entrepreneur's Relief
In allowing the taxpayer's appeal, the First-tier Tribunal determined that an LLP had commenced trading for the purposes of Entrepreneur's Relief.
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Thinking - Blog
Tribunal confirms principal private residence relief available where development began before sale of land
In the recent Nunn case, the First-tier Tax Tribunal allowed the taxpayer's claim for principal private residence relief, where development on land began before its sale.
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Thinking - Blog
Effective case management before the Tax Tribunal
Adam Craggs and Daniel Williams consider the various stages involved in a tax appeal to the First-tier Tribunal (Tax Chamber).
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Thinking - Publication
Tax Bites – October 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
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Thinking - Blog
Tribunal allows taxpayer's appeal and confirms that non-residential SDLT rates applied
In Anne-Marie Hurst v HMRC [2024] UKFTT 00540 (TC), the First-tier Tax Tribunal allowed the taxpayer's appeal against HMRC's closure notice, in which HMRC concluded that the residential rate of SDLT was due on the purchase of a property because the sellers had used it as a 'hotel, inn or similar establishment' (HISE).
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Thinking - Publication
V@ update - September 2024
Welcome to the September 2024 edition of RPC's V@, a monthly update which provides news and analysis from the VAT world.
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Thinking - Blog
HMRC's offshore information gathering powers
This blog considers HMRC's information gathering powers and, in particular, their application to High Net Worth individuals.
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Press and Media
RPC wins 'Marketing Initiative of the Year' at Legal Business Awards 2024
International law firm RPC was named the winner of the 'Marketing Initiative of the Year' at the prestigious Legal Business Awards 2024. This accolade highlights the firm's innovative approach in empowering the tax industry through cutting-edge digital solutions, setting new standards for client service and industry leadership.
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Thinking - Podcast
Taxing Matters: Taxation of agents' fees in the football industry
In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes and Investigations team, is joined by colleague and Partner, Michelle Sloane, to discuss the latest issues surrounding the taxation of agents' fees in the football industry.
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Thinking - Blog
Tribunal awards costs against HMRC due to its unreasonable conduct
In Witton v HMRC [2024] UKFTT 489 (TC) (TCC), the First-tier Tribunal allowed HMRC's applications to amend its list of documents and to admit further evidence, and refused to disbar them from proceedings, but nonetheless awarded the taxpayer his costs due to HMRC's unreasonable behaviour.
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Thinking - Blog
Tribunal allows taxpayer's post-cessation trade relief claim as enquiry was out of time
In the recent Dennison case, the FTT allowed the taxpayer's post-cessation trade relief claim as HMRC's enquiry was opened out of time.
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Thinking - Publication
Tax Bites – September 2024
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
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Thinking - Blog
Tribunal allows taxpayer's appeal in part in case concerning deliberate and/or careless errors
In Shaun Harte v HMRC [2024] UKFTT 00493 (TC), the First-tier Tribunal reduced HMRC's assessments to income tax, penalties and VAT. It also considered HMRC's application of the 'presumption of continuity' in relation to deliberate and/or careless errors.
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Thinking - Publication
V@ update - August 2024
Welcome to the August 2024 edition of RPC's V@, a monthly update which provides news and analysis from the VAT world.
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Thinking - Blog
Contentious Tax August 2024
Contentious Tax Quarterly Review - Adam Craggs and Harry Smith examine developments in relation to open justice, access to pleadings and the taxation of carried interest.
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Thinking - Publication
Customs and excise quarterly update - August 2024
Welcome to the August 2024 edition of RPC's Customs and Excise Quarterly Update. ate.
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Thinking - Blog
Upper Tribunal confirms that anti-abuse provision in UK/Ireland double tax treaty did not apply
In HMRC v Burlington Loan Management DAC [2024] UKUT 152 (TCC), the Upper Tribunal held that the anti-abuse rule in the UK/Ireland double tax treaty did not apply to deny the withholding exemption, when a Cayman Islands company assigned the benefit of a debt to an Irish company.
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