Past Issues Archive
This archive covers all the articles that appeared in the magazine at least 6 months ago. Enjoy.
April / May 2025
The good, the bad and the ugly by Gary Brothers
In the second of a three-part series, Gary Brothers talks through some of the cases his firm has taken through the Alternative Dispute Resolution...
Taming the future by Fiona Campbell
Fiona Campbell outlines the path for a future of responsible AI deployment in the UK Artificial intelligence (AI) is no longer a vision of...
Tackling the schemers by Amanda Perrotton
HMRC is finally fighting back against the promoters of anti-avoidance schemes. Amanda Perrotton explains all.Stamp Duty Land Tax (SDLT), introduced in the Finance Act...
Mind the tax gap by Nicola Kelleher
Nicola Kelleher explains the ways by which HMRC can close the tax gap.The tax gap was estimated at £39.8 billion or 4.8% of tax...
Is this the best HMRC can do? by Tony Margaritelli
Tony Margaritelli highlights a case where the tax authority consistently failed a taxpayer – then simply recommended she complain.In March I came across a...
Is HMRC really closing in on promoters? by Mala Kapacee
Mala Kapacee runs the rule over HMRC’s latest move to tackle tax avoidance. So will it really tackle the deep-lying issues?HMRC has (finally) had...
How small is small? by Dave Chaplin
How do the changes to small business thresholds affect IR35/off-payroll? Dave Chaplin explains all.The government’s recent changes to the ‘small company’ thresholds are designed...
Gino’s Contraband: a sorry tale by Tony Margaritelli
Tony Margaritelli reviews a tale of HMRC failing an honest person (sorry ‘customer’).I picked up the book ‘Gino’s Contraband’ following a posting by Dave...
Future perfect? by Paul Rosser
Paul Rosser charts the rise and rise of AI in the tax consultancy space.Like most advances in technology, people don’t really pay much attention...
A question of Control by Seb Maley
Seb Maley explains how the impact of a long-running and undecided employment status case is already playing out.The issue of employment status never seems...
A load of junk by Nick Davies
Nick Davies comments on the recent case of Rohit Kotecha v HMRC, in which an application to reinstate an appeal was successful despite the...
February / March 2025
An inspirational poll by Gary Brothers
In a three-part series, Gary Brothers examines the Alternative Dispute Resolution process, starting with an overview of what ADR is.I recently ran a poll...
Softly, softly… by Sarah Mawson
Nudge letters are a powerful tool for tax compliance, says Sarah Mawson.It’s no secret that HMRC’s use of nudge letters has become a key...
It’s good to talk by Waqar Shah
Waqar Shah explains why mediation is very often the best course to take to resolve a contentious tax matter with HMRC.In a perfect world...
Out in the cold by Paul Rosser
Paul Rosser explains how a fridge landed an R&D advisor in hot water.It was back in August 2021 when a Robert Paterson, MD of...
Employment Rights Bill: the lowdown by Rhiannon Davies
Rhiannon Davies outlines the implications of the ERB and explains what organisations need to do to comply with it.The Employment Rights Bill (ERB), announced...
Disguised Remuneration: a possible resolution by Matt Hall
Matt Hall focuses on what he hopes will be the denouement of the Loan Charge ‘scandal’.In the 2024 Autumn Budget, the government promised to...
The Loan Charge scandal: what next? by Matt Hall
Matt Hall explains the part HMRC had to play in the so-called Loan Charge scandal.The announcement on 23 January 2025 of the Loan Charge...
Expat-ily ever after? by Andy Wood
Andy Wood asks: are the changes announced in the Autumn Budget 2024 a fairy tale for long-term expats?Once upon a time – so the...
PAC pulling no punches by Simon Watkins
The Public Accounts Committee has slammed HMRC’s ‘kid gloves’ approach to tax gap and criminal prosecutions, writes Simon Watkins of TaxWatch.A political scuffle has...
Cryptocurrency: the UK tax implications by David Conway
HMRC is taking a greater interest in the tax affairs of crypto investors, so make sure clients know the rules, says David Conway.
From talk...
Choose one! by Mark McLaughlin
Mark McLaughlin looks at HMRC discovery assessments issued on an alternative basis.
Some years ago, there was a sketch on the satirical television show Spitting...
December / January 2025
‘Baseless’ concerns – or not? by Tony Margaritelli
HMRC needs to take a long, hard look at how it manages the nation’s tax affairs and how it deals with taxpayers, says Tony...
You told me to do it… didn’t you? by Mark McLaughlin
Mark McLaughlin looks at whether an innocent misunderstanding of advice given by HMRC can represent a reasonable excuse for penalty purposes.
Tax practitioners of a...
Why HMRC is part of the R&D problem by Paul Rosser
Paul Rosser explains the true cost of the R&D tax relief scandal and reveals who is to blame.
As I’ve written about previously, those behind...
The CIS: some cautionary tales by David Brindley and Jas Jhooty
David Brindley and Jas Jhooty set out some of the common pitfalls in the Construction Industry Scheme (CIS), including examples of where things can...
New ways to tackle non-compliance by Mala Kapacee
Mala Kapacee runs the rule over the Tax Administration Framework Review, and questions whether it will make tax collection more efficient and fairer.
As often...
IR35 and intermediaries: have we lost the plot? by Peter Vaines
Peter Vaines bemoans the lack of clarity and uniformity when it comes to decisions around individual’s tax bills – particularly when it comes to...
How’s your luck? by Andrew Park
Data shows a huge variation in success rates in challenging decisions across HMRC departments, writes Andrew Park.
Decisions taken against taxpayers by HMRC vary considerably...
Gone but not forgotten? by Gary Brothers
Gary Brothers probes HMRC’s ongoing pursuit of ‘rogue’ company directors by lifting the ‘corporate veil’.
In what seems like forever ago now, Schedule 13 Finance...
Fast forward by Sara Scala
The Contentious Tax Group’s Sarah Scala explains the steps to take to speed up an HMRC enquiry.
There is no limit on how long HMRC...
Budget buzz: unpacking tax disputes by Sarah Mawson
The farmers may have hogged the spotlight, but there were plenty of other matters arising from Rachel Reeves’ first Budget, writes Sarah Mawson.
The recent...
October / November 2024
Why privacy should prevail by Krishna Mahajan
Krishna Mahajan explores a taxpayer’s right to privacy during an HMRC enquiry – from it being opened to ultimate closure.
Privacy and confidentiality in tax...
VAT partial exemption: the pitfalls by Nick Davies
Nick Davies explains the rule around VAT partial exemption and business non-business.Apart from land and property, this is probably the most complex and misunderstood...
Time out by Alexis Armitage
The FTT has allowed taxpayer’s post-cessation trade relief claim as HMRC’s enquiry was out of time. Alexis Armitage explains all.In Anthony Dennison v HMRC...
The third answer by Tony Monger
Tony Monger travels through time to get to the roots of the tax authority’s current ills.In my 47-year career in taxes – 25 years...
Risky business by Danielle Ford
Danielle Ford runs the rule over HMRC’s compliance risk review process.HMRC has always carried out a large volume of compliance activity through enquiries and...
Out of time? by Mark McLaughlin
Mark McLaughlin looks at the time limits for HMRC to open self-assessment tax return enquiries and to give individual taxpayers notice of its intention...
Account Freezing Orders skyrocket by Michelle Sloane and Keziah Mastin
Michelle Sloane and Keziah Mastin consider HMRC’s dramatic increase in the use of Account Freezing Orders (AFOs) and Forfeiture Orders (FOs) over the past...
Flexibility by Sean Wakeman
Sean Wakeman relates a tax case that highlights how HMRC’s inflexibility and intransigence betrays the interests of all taxpayers.
The recent case of Majid v...