Past Issues Archive

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

February / March 2021

“Comment: Points make prizes and a job in the TPF beckons” by Tony Margaritelli, Publisher, HMRC EIP

The annual Budget has just been presented to Parliament and our inboxes are groaning under the strain of emails offering ‘Budget Updates’; actually, this year’s affair was full of amendments and updates that warrant a long hard look, writes Tony Margaritelli.

“Joint Liability Notices: be afraid…” by David Lewis, Senior Manager in Mazars Tax Investigations Team and Haris Rehman, Manager in Mazars Tax Investigations.

With the Joint Liability Notice, the taxman has added a powerful weapon to his armoury. David Lewis and Haris Rehman explain what a JLN is and how it has come about.

“Is the taxman’s word his bond?” by Mala Kapacee, specialist in preparation of disclosures to HMRC and resolution of tax enquiries

Mala Kapacee highlights a troubling case involving an HMRC-approved tax scheme that caused huge anxiety when the Revenue changed its mind.

“Permission denied!” by Les Howard, partner in vatadvice.org, a specialist VAT practice based in Cambridgeshire

Les Howard highlights a case where HMRC removed a company’s permission to use the Cash Accounting Scheme.

“Right and wrong” by Elliot Green, CEO of Oliver Elliot

What is wrongful trading? Elliot Green explains all – and questions whether the Government’s decision to suspend the wrongful trading rules last year was a wise one.

“So who’s to blame?” by Jack Prytherch, senior associate in Bird & Bird’s tax disputes and investigations team

Jack Prytherch examines the issues around a failure to file returns by third parties and the imposition of ‘deliberate’ penalties.

“The long arm of HMRC” by Adam Craggs, partner at RPC LLP. and Alice Kemp, employed barrister at RPC LLP

Adam Craggs and Alice Kemp outline the powers HMRC has at its disposal when conducting a criminal rather than civil investigation.

“Tipping the scales” by Robin Williamson MBE, CTA (Fellow), author and commentator on tax and welfare issues

How is HMRC faring in its mission to strike the right balance between its powers and taxpayer safeguards? Robin Williamson reports.

“Case defeats cost HMRC millions in legal costs”

HMRC spent more than £2m in legal costs following lost cases in 2019/20, according to research by law firm Pinsent Masons. This represented an 88% hike in the amount HMRC shelled out in legal costs to taxpayers for the period.

December / January 2020

“Dealing with dawn raids” by Jack Prytherch, senior associate in Bird & Bird’s tax disputes and investigations team

Jack Prytherch explains what you should do if your business is raided by HMRC, and how you should react to it afterwards.

“Getting back up to speed with IR35” by Becky Hardy, CTA-qualified, originally starting her tax career with Grant Thornton in 2006

With the pandemic and Brexit dominating you might have taken your eye off the IR35 ball. Here Becky Hardy outlines the state of play and what will be happening in 2021.

“Going for gold?” by Gary Brothers, Partner, The Independent Tax & Forensic Services LLP

Are you aware of the Criminal Finance Act 2017?If not, you should be, says Gary Brothers.

“Information notices: how far back?” by Mark McLaughlin CTA (Fellow) ATT (Fellow) TEP, consultant with The TACS Partnership LLP

Mark McLaughlin looks at how many prior years HMRC information notices can potentially stretch Information notices are an important and frequently-used weapon in HMRC’s vast array of compliance powers. HMRC have powers to obtain information and documents, and can issue an information notice requiring the taxpayer to provide information or produce a document if it is ‘reasonably required’ to check the taxpayer’s tax position (FA 2008, Sch 36, para 1).

“Insolvency and tax avoidance: a rude awakening” by Elliot Green, tax and insolvency specialist and CEO of Oliver Elliot

Is insolvency a Director’s useful response to the consequence of tax avoidance schemes? Could the taxpayer be storing up further trouble and potentially even a bigger bill, asks Elliot Green.

“TOGC: all together now” by Les Howard, partner in vatadvice.org, a specialist VAT practice based in Cambridgeshire

Les Howard reports of a recent tribunal case complicated by a Transfer of Going Concern (TOGC).

“Tackling the tax gap” by David Pedley, Senior Manager within the Tax Dispute Resolution team at Grant Thornton UK LLP; and Sarah Mawson, associate...

David Pedley and Sarah Mawson explain what the tax gap is, how it is calculated, and what HMRC is doing to try to reduce it.

“Timing is key to a successful appeal” by Jesminara Rahman, Director of Tax Resolute

Jesminara Rahman explains how to submit an appeal to HMRC, and why it’s vital you act in a timely manner.

October / November 2020

“The future of tax compliance is digital” by Jesminara Rahman, Director of Tax Resolute

Jesminara Rahman explains what you need to know to about digital records to prepare for the digitalisation of tax compliance.

“Seeing reason” by Robin Williamson MBE CTA (Fellow), author and commentator on tax, welfare and public policy

The tribunal is the arbiter of fact when it comes to the reasonable excuse defence, says Robin Williamson, who explains all with reference to some recent cases.

“Safeguarding share schemes” by JD Ghosh, law graduate of University of London

JD Ghosh of Winslows Tax explains updates to the rules around employee share schemes.

“Improve… or else!” by Mark McLaughlin CTA (Fellow) ATT (Fellow) TEP, consultant with The TACS Partnership LLP

Mark McLaughlin looks at penalties for errors in tax returns, etc. attributable to someone other than the taxpayer, and possible future sanctions against tax advisers.

“How far can HMRC go?” by Mala Kapacee specialist in preparation of disclosures to HMRC and resolution of tax enquiries

Now the loan charge deadline has passed, it’s time for us to take a step back and look at how the relationship between HMRC and the profession has evolved, writes Mala Kapacee.

“HMRC letters: ‘Your offshore assets, income or gains’” by Helen French, Senior Tax Manager at Frank Hirth and Kugan Panchalingam, Senior Tax Manager at...

Kugan Panchalingam and Helen French discuss HMRC’s increasing use of so-called nudge letters to prompt taxpayers into paying more tax.

“Corporate Criminal Offence: three years on” by Sarah Mawson and David Francis, Head of Tax Dispute Resolution, Grant Thornton UK LLP

Sarah Mawson and David Francis of Grant Thornton explain why businesses both large and small must protect themselves against third-party tax fraudsters.

“ADR: what’s it all about then?” by Paul Clarke, Tax Resolution Director at Brown Butler Chartered Accountants

Paul Clarke explains which type of disputes are suited to the Alternative Dispute Resolution, and shares some examples of where it has worked.