Past Issues Archive

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

February / March 2022

The devil’s in the detail by Les Howard, partner in, a specialist VAT practice based in Cambridgeshire

A recent tribunal case shed some light on legitimate expectation, writes Les Howard. Legitimate expectation takes many forms, from...

Should we pretend? by Mark McLaughlin CTA (Fellow) ATT (Fellow) TEP,Editor, co-author of HMRC Investigations Handbook (Bloomsbury Professional)

Mark McLaughlin looks at HMRC’s use of the ‘presumption of continuity’ when assessing additional income for periods other than the period of...

Resources and the investigation of economic crime by Aziz Rahman, Senior Partner at financial crime specialists Rahman Ravelli

A hard-hitting report has stated that the UK’s efforts to tackle such crime is being hampered by underfunding. Aziz Rahman considers the...

Know your rights by Jesminara Rahman, Director of Tax Resolute

Jesminara Rahman explains the human rights HMRC has to safeguard when they are dealing with a taxpayer. There are...

How to deal with inexperienced HMRC officers by Dave Wase, PKF Francis Clark Tax Advisory Service

Dave Wase explains the best tactics to employ when you are dealing with Revenue staff who are new to the job.

How does HMRC investigate cryptocurrencies? by Salman Anwar, Associate Director in BDO’s Tax Dispute Resolution team

Cryptocurrencies are becoming an increasingly important part of the global financial landscape. Salman Anwar looks at the UK’s tax authority’s approach to...

HMRC delays escalate by Justin Stevenson, Associate Director, RSM UK Tax and Accounting Limited.

The extended wait for refunds is unacceptable, says Justin Stevenson. Here he explains why. HMRC resources have been understandably...

Cryptocurrency: could you require a HMRC disclosure? by Antony Greenwood, Manager (Tax Investigations), Buzzacott

Antony Greenwood explains how cryptocurrency should be treated for tax purposes. HMRC released its guidance on how cryptocurrency should...

Ask the experts by Associate Partner at Claritas Tax, head of Tax Dispute Resolution

Sarah Scala takes a closer look at the role of an expert witness in a professional negligence claim. When...

December / January 2022

Car rental payments decision has NMW implications

The Employment Appeal Tribunal has ruled that car rental payments were ‘in connection with the employment’ and reduced pay for National Minimum...

Can you Backdate your salary? by Elliot Green, tax and insolvency specialist and CEO of Oliver Elliot

Elliot Green highlights a case involving an Overdrawn Directors Loan Account that every director should commit to memory. The...

How HMRC can improve in 2022 by Graham Webber, Director of Tax at WTT Consulting

‘Could do better’ is what Graham Webber would write on the taxman’s end-of-year report. Here he offers a few suggestions about where...

Bouncing back badly by Syed Rahman, Partner at financial crime specialists Rahman Ravelli

Syed Rahman examines the fraud-friendly faults that have been highlighted in the government’s Bounce Back Loan Scheme. As an...

The ‘likely’ lad: what’s in a word? by Israr Manawer, tax consultant

Israr Manawer highlights a case where a follower notice was quashed after a Judicial Review outcome was overturned by judges.

Beware financial institution notices by Jack Prytherch, tax lawyer at CMS

Is HMRC’s new power broader than it has accepted, asks Jack Prytherch. From June 2021, HMRC have the power...

Is it Safe Yet? by Mark McLaughlin CTA (Fellow) ATT (Fellow) TEP, Editor and a co-author of HMRC Investigations Handbook (Bloomsbury Professional)

Mark McLauglin looks at the time limits for HMRC to collect inheritance tax underpayments. Taxpayers generally seek finality in...

How should HMRC treat the victims of tax fraud? by George Turner, director of TaxWatch

What should be the tax liability of people who are the victims of fraud? That is the important question raised by the...

October / November 2021

“Why CIS is not just for construction firms” by David Williams-Richardson and RSM’s Lee Knight

David Williams-Richardson and Lee Knight explain the wider implications of the construction industry scheme.' While the construction industry scheme...

“Taking the credit” by Mark McLaughlin CTA (Fellow) ATT (Fellow) TEP is Editor and a co-author of HMRC Investigations Handbook (Bloomsbury Professional)

Mark McLaughlin looks at the timing of receipts to directors’ loan accounts for the purposes of establishing the potential liability to tax...

“Reasonable excuse defence” by Les Howard, partner in, a specialist VAT practice based in Cambridgeshire

Les Howard explains the vagaries and subtleties of the ‘reasonable excuse’ argument. The single Tax Tribunal regime means that...

“Opportunities knock” by Danielle Ford, Head of Tax Disputes and Resolutions at Haysmacintyre LLP.

Danielle Ford and Riocard Hoye explain HMRC’s recently announced settlement opportunity relating to the Eclipse film schemes. On 6...

“IR35 explained” by Dave Chaplin, CEO of IR35 compliance solution IR35 Shield and author of IR35 & Off-Payroll Explained

Self-confessed ‘IR35 addict’ Dave Chaplin takes a tongue-in-cheek look at the bizarre world he’s inhabited for the past 20 years.

“Inadequate customer due diligence” by Rachel Clark, barrister at Bright Line Law

Rachel Clark looks at a case where it was established that a law firm had no duty to investigate client’s struck-off solicitor...

“How to set aside an HMRC follower notice” by Elliot Green FCA FABRP

Setting aside an HMRC follower notice led one taxpayer to the Supreme Court, writes Elliot Green. Follower Notices were...

“HMRC gets a pizza the action” by Anton Lane, industry recognised specialist with contentious tax issues

Anton Lane looks at a case where ‘the Pizza Guy’ didn’t know that HMRC can obtain information from merchant acquirers.

“A better alternative just around the block” by Hugh Gunson (Partner) and Guy Bud (Associate Barrister), Charles Russell Speechlys LLP

Hugh Gunson and Guy Bud explain the experiences of start-up Fashion on the Block after in inadvertently filed the wrong form with...

August / September 2021

‘Whenever, wherever’ by Andy Wood, experieanced Tax Advisor and Barraster at etcTAX

Andy Wood describes how HMRC has taken a leaf out of its Spanish counterpart’s book when it comes to celebrity taxpayers.

‘Tax Records Going Digital’ by Jesminara Rahman, Tax Investigaitons Specialist and Director of Tax Resolute

Jesminara Rahman explains how tax going digital will have an impact on the records that HMRC can request.

‘Sweet and Sour Tax’ by Keith Gordon, Barrister at Temple Tax Chambers

Keith Gordon focuses on a Tribunal case in which HMRC failed to satisfactorily back up its supposition that a Chinese restaurant was not playing by the book.

‘HMRC Serious Tax Investigations’ by Amit Puri, Head of Lancaster Knox’s Tax Investigations & Disputes Practice

Amit Puri examines the latest Codes of Practice 8 and 9 tax investigations statistics and shares his insights on what they mean.

‘HMRC Factsheets’ by Gary Brothers, Partner, The Independant Tax & Forensic Services LLP

What information is out there to help you when it comes to an HMRC investigations? Gary Brothers explains all.

‘Help Yourself’ by Mark McLaughlin CTA (Fellow) AAT (Fellow) TEP, is a consultant with The TACS Partnership LLP

Mark McLaughlin warns that if taxpayers don’t keep full and accurate records, HMRC could help themselves to additional tax that would not otherwise be due.

‘Groundhog Day for Employment Allowance Scam’ by Robin Williamson, MBE CTA (Fellow), Author and Commentator on Tax

Robin Williamson highlights egregious tax evasion schemes through the utilisation of miniumbrella companies While listening to BBC’s File on 4 ‘Britain’s Ghost Companies’ in May, I experienced a distinct sense of déjà vu.

‘Getting Offshore Tax Right’ by Anton Lane, Industry Recognised Specialist with Contentious Tax Issues

Anton Lane examines the implications and subtleties of HMRC’s drive to help ‘taxpayers get offshore right’.

‘Can You Backdate a Limited Company Dividend’ by Elliot Green, CEO of Oliver Elliot

The short answer is no! You cannot backdate the dividends of a limited liability company to its owners. Elliot Green explains why.

‘Calling In the Experts’ by Mala Kapacee, specialist in preparation of disclosures to HMRC

Why should you use a tax investigations specialist and when? Mala Kapacee shares her thoughts on these important questions.