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HMRC's offshore information gathering powers

Published on 19 Sep 2024. By Liam McKay, Senior Associate and Michelle Sloane, Partner

This blog considers HMRC's information gathering powers and, in particular, their application to High Net Worth individuals.

RPC wins 'Marketing Initiative of the Year' at Legal Business Awards 2024

Published on 18 Sep 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.

Taxing Matters: Taxation of agents' fees in the football industry

Published on 17 Sep 2024.

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.

Tribunal awards costs against HMRC due to its unreasonable conduct

Published on 12 Sep 2024.

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.

Tribunal allows taxpayer's post-cessation trade relief claim as enquiry was out of time

Published on 05 Sep 2024. By Alexis Armitage, Senior Associate

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.

Tax Bites – September 2024

Published on 03 Sep 2024. By Adam Craggs, Partner

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

Tribunal allows taxpayer's appeal in part in case concerning deliberate and/or careless errors

Published on 29 Aug 2024. By Jasprit Singh, Senior Associate

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.

V@ update - August 2024

Published on 27 Aug 2024. By Adam Craggs, Partner

Welcome to the August 2024 edition of RPC's V@, a monthly update which provides news and analysis from the VAT world.

Contentious Tax August 2024

Published on 22 Aug 2024. By Adam Craggs, Partner

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.

Customs and excise quarterly update - August 2024

Published on 21 Aug 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

Welcome to the August 2024 edition of RPC's Customs and Excise Quarterly Update. ate.

Upper Tribunal confirms that anti-abuse provision in UK/Ireland double tax treaty did not apply

Published on 15 Aug 2024.

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.

Upper Tribunal confirms it’s the end of the road for HMRC's "fishing expedition"

Published on 08 Aug 2024. By Alexis Armitage, Senior Associate

In the recent Hitchins case, the Upper Tribunal confirmed that it was the end of the road for HMRC's "fishing expedition" and ordered it to close its enquiries.

Closure notices and the appeals process

Published on 01 Aug 2024. By Adam Craggs, Partner and Liam McKay, Senior Associate

In this article we consider the process by which a taxpayer can bring a protracted HMRC enquiry to and end and appeal against a closure notice issued by HMRC.

Tax Bites – August 2024

Published on 31 Jul 2024. By Adam Craggs, Partner

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

HNWs: Understanding HMRC's Offshore Information Gathering Capabilities

Published on 24 Jul 2024. By Michelle Sloane, Partner and Liam McKay, Senior Associate

Wealthy individuals have long been the focus of a substantial part of HMRC’s compliance activities, but a difficult economic climate together with a looming general election and possible change of government is likely to lead to even greater scrutiny of HNWs by HMRC in the short term.

V@ update – July 2024

Published on 23 Jul 2024. By Adam Craggs, Partner

Welcome to the July 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world.

Tribunal confirms no tax due on disposal of property held on trust for taxpayer's brother

Published on 18 Jul 2024.

In Raveendran v HMRC [2024] UKFTT 273 (TC), the First-tier Tribunal allowed the taxpayer's appeal against HMRC's discovery assessment in relation to the disposal of a property because it was held on trust for his brother.

Taxing Matters: Spotlight 63: HMRC shines a light on property business arrangements involving hybrid partnerships

Published on 16 Jul 2024.

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Simon Howley and Amanda Perrotton from Bell Howley Perrotton LLP. They discuss HMRC's Spotlight 63, which focuses on property business arrangements involving hybrid partnerships, which have recently come to the attention of HMRC.

Tribunal confirms loans from remuneration trust were disguised remuneration

Published on 11 Jul 2024. By Liam McKay, Senior Associate

In allowing HMRC's appeal in part, the Upper Tribunal determined that payments received under a remuneration trust scheme were caught by the anti-avoidance provisions in Part 7A of the Income Tax (Earnings and Pensions) Act 2003.

Dealing with HMRC information notices

Published on 04 Jul 2024. By Adam Craggs, Partner and Daniel Williams, Associate

Considering three common types of HMRC information notices and the extent to which they can be challenged.

Tax Bites – July 2024

Published on 02 Jul 2024. By Adam Craggs, Partner

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

V@ update – June 2024

Published on 26 Jun 2024. By Adam Craggs, Partner

Welcome to the June 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world.

Tribunal awards taxpayer his costs due to HMRC's unreasonable conduct

Published on 20 Jun 2024. By Jasprit Singh, Senior Associate

In Aftab Ahmed v HMRC [2024] UKFTT 00236 (TC), the First-tier Tribunal granted the taxpayer's application for costs as HMRC had acted unreasonably in defending the appeal.

Tribunal allows entrepreneurs' relief appeal

Published on 13 Jun 2024.

In Cooke v HMRC [2024] UKFTT 272 (TC), the FTT allowed the taxpayer's appeal against HMRC's refusal of entrepreneurs' relief

Exploring tax from an ESG perspective

Published on 07 Jun 2024.

In this month's episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Paul Monaghan, Chief Executive and co-founder of the Fair Tax Foundation to discuss the growing interest in tax from an ESG perspective, and the work of the Fair Tax Foundation.

What happens in an HMRC criminal investigation

Published on 06 Jun 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

Tax Bites – June 2024

Published on 05 Jun 2024. By Adam Craggs, Partner

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

Tribunal dismisses HMRC's appeal and confirms transactions did not give rise to a taxable remittance

Published on 30 May 2024. By Liam McKay, Senior Associate

In dismissing HMRC's appeal, the Upper Tribunal confirmed that transactions entered into by the taxpayers for the sale of shares did not amount to a taxable remittance under section 809L of the Income Tax Act 2007 because no service was provided in the UK.

Key features of the new non-UK domicile regime

Published on 29 May 2024. By Michelle Sloane, Partner and Jasprit Singh, Senior Associate

The UK government's unexpected announcement in Spring Budget in March on the taxation of non-domicile individuals has sparked concerns and much comment. It represents a major change to the current system of taxation, which is more than 200 years old.

V@ update – May 2024

Published on 28 May 2024. By Adam Craggs, Partner

Welcome to the May 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world.

Customs and excise quarterly update - May 2024

Published on 21 May 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

Welcome to the May 2024 edition of RPC's Customs and Excise Quarterly Update.

The latest on the loan charge scandal with Matt Hall from Armadillo

Published on 21 May 2024.

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Chartered Tax Adviser, Matt Hall from Armadillo to discuss the latest on what is often referred to as the "loan charge scandal".

Taxpayers' application for  protective costs order against HMRC refused

Published on 20 May 2024. By Alexis Armitage, Senior Associate

UT dismisses taxpayer's application for a protective costs order against HMRC.

Contentious Tax Update

Published on 16 May 2024. By Adam Craggs, Partner

Harry Smith and Adam Craggs examine developments in relation to DOTAS, R&D enquiries, and the Economic Crime and Transparency Act.

Tribunal allows taxpayer's appeal in R&D case against penalty assessment for careless inaccuracy

Published on 03 May 2024. By Jasprit Singh, Senior Associate

In H & H Contract Scaffolding Ltd v HMRC [2024] UKFTT 00151 (TC), the First-tier Tribunal (FTT) allowed the taxpayer's appeal against a penalty assessment as the inaccuracy in the tax return was not careless.

Tax Bites – May 2024

Published on 01 May 2024. By Adam Craggs, Partner

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

Contentious tax quarterly: Spring review

Published on 01 May 2024. By Adam Craggs, Partner

The last few months have seen a flurry of activity in relation to the DOTAS regime, with HMRC seeking to register arrangements retrospectively and apply substantial penalties for failure to register. Woes continue for those unfortunate enough to have R&D claims under enquiry, and the Economic Crime and Corporate Transparency Act 2023 gives HMRC a significant new tool in relation to suspected criminal activity by bodies corporate and partnerships.

Changes to non-domiciliary rules with Philip Simpson KC and Ben Symons

Published on 30 Apr 2024.

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team is joined by Philip Simpson KC and Ben Symons from Old Square Tax Chambers, to discuss the Government's Spring Budget and, in particular, the proposed changes that will affect non-UK domiciled individuals.

V@ update – April 2024

Published on 24 Apr 2024. By Adam Craggs, Partner

Welcome to the April 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.

Costly objection by HMRC

Published on 15 Apr 2024.

FTT allows costs application where HMRC acted unreasonably in opposing specific disclosure application.

Tax Bites – April 2024

Published on 03 Apr 2024. By Adam Craggs, Partner

Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

V@ update - March 2024

Published on 26 Mar 2024. By Adam Craggs, Partner

Welcome to the March 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.

International Women's Day special – Inspiring inclusion with Tax Titan Trio

Published on 08 Mar 2024.

To celebrate International Women's Day 2024, we have produced a special episode of RPC's Taxing Matters podcast in which we discuss this year's campaign theme #InspireInclusion and what it means to each of our guest speakers.

Tax Bites - February 2024

Published on 07 Mar 2024. By Adam Craggs, Partner

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

V@ update - February 2024

Published on 28 Feb 2024. By Adam Craggs, Partner

Welcome to the February 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.

Customs and excise quarterly update - February 2024

Published on 28 Feb 2024. By Adam Craggs, Partner and Michelle Sloane, Partner

Welcome to the February 2024 edition of RPC's Customs and Excise Quarterly Update.

A whistlestop tour of the taxation of international sports and rock stars with Patrick Way KC

Published on 21 Feb 2024.

In this episode, RPC's Taxing Matters Host and Senior Associate in RPC's Tax Disputes team, Alexis Armitage, will be discussing the taxation of international sports and rock stars with leading silk, Patrick Way KC.

Tax Bites - January 2024

Published on 31 Jan 2024. By Adam Craggs, Partner

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

Exploring the World of AI with Olivia Dhein

Published on 30 Jan 2024.

In this episode we discuss the hot topic of artificial intelligence. We will consider what is AI, what is a large language model and how does it work, what can AI do and not do at the moment as well as some of the potential effects AI might have in the tax world. We also take a look at the recent Tax Tribunal decision in Harber v HMRC [2023] UKFTT 1007 (TC), in which false case law was generated by AI and innocently relied upon by the taxpayer and how the Tribunal dealt with this.

V@ update - January 2024

Published on 24 Jan 2024. By Adam Craggs, Partner

Welcome to the January 2024 edition of RPC's V@, a monthly update which provides insightful analysis and news from the VAT world relevant to your business.