Past Issues Archive
This archive covers all the articles that appeared in the magazine at least 6 months ago. Enjoy.
February / March 2023
‘To prosecute or not to prosecute’ by Nigel Brown, tax expert at Trident Tax
Nigel Brown explains the dilemma HMRC faces when deciding whether or not to take a fraud case through the courts.
In 2016 HMRC’s Fraud Investigation...
‘The taxman’ by Patrick Way KC, barrister at Field Tax
Patrick Way KC discusses the tax issue that may arise when an artist sells their back catalogue.
Many rock musicians are selling their rights in...
‘Salary advances’ by Susan Ball, Partner, RSM. and Joe Pickering, Associate Director, Employer Solutions, RSM
Salary advances are becoming more commonplace as the cost-of-living crisis bites. Susan Ball and Joe Pickering explain what they are and what factors an...
‘Plus ca change’ by Matt Hall, Director at Armadillo
Plus ca change…?
Matt Hall reminisces about his days working for the Inland Revenue, and wonders if anything has actually changed since that time HMRC...
‘Penalties’ by Mark McLaughlin CTA (Fellow) ATT (Fellow) TEP, Editor and a co-author of HMRC Investigations Handbook (Bloomsbury Professional)
Mark McLaughlin highlights a difficulty that can sometimes arise in the calculation of penalties for errors in tax returns.
Taxpayers who submit tax returns to...
‘Lies’ by Tony Monger, former HMRC investigator and investigation team leader
Tony Monger highlights a particularly egregious case where an HMRC invigilation came up with some very fishy conclusions.
Every three months HMRC publishes a list...
‘Director disqualification proceedings explained’ by Elliot Green, founder and CEO of Oliver Elliot
Elliot Green explains how the process works, and why it’s vital a director facing disqualification should seek expert advice.
Director disqualification proceedings arise from an...
‘Be afraid’ by Seb Maley, CEO of Qdos Contractor
Seb Maley explains why we should all be wary of a better-resourced HMRC.
The government will spend an additional £79m to fight tax fraud as...
December / January 2023
“HMRC criminal investigations activity: an update” by George Gillham, Partner and Head of Contentious Tax at Fieldfisher LLP and Jade McCauley, Paralegal at Fieldfisher...
George Gillham and Jade McCauley crunch the numbers, and offer some practical advice on dealing with an HMRC investigation.
This article is aimed at tax...
“It’s a privilege!” by Mark McLaughlin CTA (Fellow) ATT (Fellow) TEP, Editor and a co-author of HMRC Investigations Handbook (Bloomsbury Professional)
Mark McLaughlin looks at the legal professional privilege exception from providing documents requested in HMRC information notices.
Information notices have been a key weapon in...
“HMRC is watching you!” by Sian Marsden, Tax Manager, RSM UK
Sian Marsden explains how HMRC utilises a wide range of sources to gauge whether the right amount of tax has been paid.
HMRC receives lots...
“Lack of accuracy costs charity dear” by Les Howard, freelance VAT Consultant, working mainly alongside vatadvice.org, a specialist VAT advisory practice
Les Howard explains why clear communication and keeping concise records are of paramount importance.
A combination of complex VAT matters and less-than-accurate documentation is a...
“Money laundering cases: prosecutions” by John Binns, partner at BCL Solicitors LLP
In the second of his two-part series, John Binns asks the question: is a prosecution inevitable?
Given the seriousness with which the Proceeds of Crime...
“Have you had a ‘nudge’ from HMRC?” by Danielle Ford, Director and Head of Tax Disputes & Resolutions at Haysmacintyre and Riocard Hoye,...
Danielle Ford and Riocard Hoye explain the proliferation of so-called ‘nudge letters’ from HMRC, and have some advice on what to do if a...
“Putting a stop to tax fraud – but how?” by Mala Kapacee, CTA Director
Mala Kapacee discusses the ins and outs of the joint APPG/Taxwatch proposal on the way HMRC treats promoters of tax avoidance schemes.
In October 2022,...
“Where’s the deterrent?” by Alex Dunnagan, Acting Director, TaxWatch
The funding of HMRC’s Taxpayer Protection Taskforce raises serious questions about whether it was the best approach to dealing with Covid fraud, writes Alex...
“Timing is everything” by Rachael Brown, Private Client Tax Manager, Claritas Tax
Rachael Brown outlines some of the implications of HMRC’s decision to align all basis periods with the tax year.
Big changes are on the horizon...
“Why it pays to ask an expert” by Sarah Scala, Associate Partner and Head of Tax Dispute Resolution at Claritas Tax
Sarah Scala explains the practicalities of involving a tax dispute resolution specialist in a dispute between your client and HMRC.
In this article I explain...
October / November 2022
“Get on the front foot” by Gary Brothers, partner at Independent Tax and Paul Rippon, Assistant Manager, Independent Tax
Gary Brothers and Paul Rippon explain how HMRC’s Time to Pay arrangements work, and have some top tips and pitfalls to avoid.
In the aftermath...
“VAT: so what’s a business activity?” by Audrey Fearing, Partner and Co-Head of NHS at RSM UK
Audrey Fearing outlines HMRC’s new approach to determining business activity for VAT purposes.
HMRC has published a new policy paper and revised guidance explaining how...
“Money laundering investigations: a practical guide” by John Binns, partner at BCL Solicitors LLP
In the first of a two-part series, John Binns explains the complex nature of money laundering investigations.
The discovery of a suspected money laundering offence...
“Off-payroll repeal: the 24 days tax advisors stood still” by Dave Chaplin, CEO of IR35 compliance solution IR35 Shield and author of IR35 &...
Lost the plot when it comes to the Off-payroll working rules? Well, you’re not alone – it seems the government has too. Here Dave...
“HMRC has digital health businesses in its sights” by Matthew Sharp, Partner at Fieldfisher
Companies working in the sector should check workers’ employment status, warns Matthew Sharp.
After a pause in compliance activity during the Covid-19 pandemic, HMRC is...
“A fair COP?” by Amit Puri, lead of Lancaster Knox’s Tax Investigations & Disputes practice
Amit Puri shares the latest Codes of Practice 8 and 9 tax investigations statistics, including 2021-22 figures straight from HMRC, and shares his insights...
“Plastic fantastic?” by Steven Porter, Partner, Head of Tax Disputes and Investigations at Pinsent Masons
Steven Porter tells you everything you always wanted to know about the Plastic Packaging Tax but were afraid to ask…
A new tax on plastic...
“Six-figure penalties!” by Mark McLauglin , CTA (Fellow) ATT (Fellow) TEP is Editor and a co-author of HMRC Investigations Handbook (Bloomsbury Professional)
Mark McLaughlin warns that not providing relevant information and documents in response to an HMRC information notice could be an expensive compliance failure Information...
“COP9 case study – the conclusion” by Anton Lane, industry recognised specialist dealing with contentious tax issues
In the final part of his three-part series, Anton Lane concludes the tale of Scott and a COP9 disclosure Six months of Scott’s life...
August / September 2022
“COP9 Case Study (part two)” by Anton Lane, industry recognised specialist dealing with contentious tax issues
This is the second part of a three-part series by Anton Lane considering how a COP9 disclosure may unfold. The final instalment will be...
“Directors Loan Accounts” by Elliot Green, tax and insolvency specialist and founder and CEO of Oliver Elliot
Can a director negotiate repayment of an overdrawn loan account with a liquidator? Elliot Green explains all.
This article is about the perennial problem of...
“Electronic Sales Suppression and HMRC” by Patrick Boyers, Solicitor in the Business Crime and Regulation team at JMW Solicitors LLP and Mike Rainford, Partner...
Patrick Boyers and Mike Rainford examine a new area of inquiry that has opened up to HMRC and is sure to be keenly pursued.
With...
“Home Thoughts From Abroad” by Richard Wynne, Senior Manager at Trident Tax
Richard Wynne explains how new legislation will impact on overseas entities who own or wants to buy and sell UK property.
Legislation for a new...
“Mediation in the Modern Age” by Craig Aspinall, Senior Manager in BDO’s Tax Dispute Resolution Team
Craig Aspinall offers some practical tips for alternative dispute resolution in the new world.
Alternative Dispute Resolution (ADR) is a formal mediation process for tax...
“No Safe Haven” by Louisa Beciri and Holly Tucker, members of the Tax Dispute Resolution team at Grant Thornton
Louisa Beciri and Holly Tucker explain the implications of the ‘landmark’ Euro Pacific Bank suspension
On 30 June 2022, Euro Pacific Bank was suspended following...
“Play Your Card Right” by Gary Brothers, partner at Independent Tax
Closure notice applications are an ace up the advisor’s sleeve, writes Gary Brothers.
As many tax advisors will know only too well, an HMRC enquiry...
“The Tax Fraud Gap” by Alex Dunnagan, Acting Director, TaxWatch
Just how accurate are HMRC’s figures for the Tax Gap? Alex Dunnagan crunches the numbers.
The pressure on HMRC to tackle tax fraud is immense....
“When ‘white space’ disclosure can help the taxpayer” by Steven Porter, Partner, Head of Tax Disputes and Investigations at Pinsent Masons
Steven Porter explains all, with reference to a recent tribunal ruling.
A recent case in the first-tier tax tribunal (FTT) provides lessons for taxpayers on...
“Will You Be Reasonable” by Mark McLauglin , CTA (Fellow) ATT (Fellow) TEP is Editor and a co-author of HMRC Investigations Handbook (Bloomsbury Professional)
Mark McLaughlin looks at HMRC’s current approach to ‘reasonable excuse’ in the context of late filing of self-assessment returns by individuals
The ‘filing season’ for...