Article Archive | HMRC: Tax Investigations

Past Issues Archive

This archive covers all the articles that appeared in the magazine at least 6 months ago. Enjoy.

December / January 2025

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...

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...

What use is a Charter if the narrative is all one way? by Tony Margaritelli

HMRC needs to listen more and dictate less, writes Tony Margaritelli.“HMRC has a clear and vital purpose – to collect the money that pays...

Tax reform tensions: a balancing act by Nick McLeman

Nick McLeman explores the tension between efficiency and safeguards in the UK’s tax administration reforms.In February of this year, I was pleased to have...

Revenue sets sights on IHT by Waqar Shah and Anna Metadjer

Inheritance tax investigations by HMRC continue to increase. Waqar Shah and Anna Metadjer outline the current state of play.Inheritance tax liabilities for the tax...

Not necessarily careless! by Mark McLaughlin

Mark McLaughlin points out that a tax return inaccuracy is not necessarily careless simply because an error was made.Tax return errors are not uncommon....

Exposing HMRC’s scrutiny of the CIS by David Brindley and Jas Jhooty

David Brindley and Jas Jhooty look at HMRC’s increased focus in the Construction Industry Scheme (CIS) space. So what’s the issue?The CIS is designed...

EV charging: VAT battle lines are forming by Scott Harwood

Scott Harwood explains how the charging of electric vehicles is creating uncertainty when it comes to the VAT rules.When new technology or innovative business...

Dear Chancellor… by Mark Morton

Mark Morton, a former tax inspector, recently published an open letter to the Chancellor of the Exchequer, Rachel Reeves MP. Here is that letter....

Action – or inaction? by Amit Puri

Amit Puri reviews HMRC action against third parties including agents and advisers – or the lack of it…We recently asked HMRC for statistics and...

Where’s the consistency? by Phil Allingan

Phil Allingan bemoans the inconsistency of HMRC’s Debt Management Department I have been negotiating Time to Pay plans with HMRC for over 16 years. During...

That’s the gamble! by Liam McKay

A recent tax tribunal upheld a taxpayer’s appeal in respect of remote gaming duty. Liam McKay explains why. In L & L Europe Ltd v HMRC...

R&D: a horror story by Paul Rosser

Paul Rosser relates a brief history of R&D advisor scams – and it makes for shocking reading... Since being introduced in 2000 for SMEs and...

How to avoid the VAT traps by Andrew Park and Greg Mayne

Andrew Park and Greg Mayne explain how you can navigate the VAT error disclosure system and explain the steps you can take to avoid...

In football, image is all… by Graham Hambly

Graham Hambly recently chaired a seminar on football finance, guest-starring four football finance experts. Here’s how the evening unfolded Tax and HMRC took centre stage...

I’m not looking for your vote – just your subscription by Tony Margaritelli

Tony Margaritelli hopes that HMRC’s problems are properly addressed after the upcoming general election As I write the upcoming election is just weeks away, and it...

HMRC disclosures: getting it right by Mala Kapacee

Mala Kapacee highlights areas to keep in mind when choosing a disclosure route, making the disclosure and communicating with HMRC after submission Disclosures to HMRC...

ESS under renewed HMRC focus by Sarah Mawson and Varoon Saccaram

Sarah Mawson and Varoon Saccaram explain what hospitality and retail businesses receiving an HMRC ESS nudge letter need to do next. Just don’t ignore...

Don’t take too long by Mark McLauglin

Mark McLaughlin looks at the timing of applications by taxpayers for the tribunal to direct HMRC to issue closure notices in tax return enquiries It is...