Coping with HMRC enquiries: some practical guidance
If an error or omission leading to a loss of tax is uncovered, a voluntary disclosure should be made to HMRC as soon as ...
Management of taxes
Management of taxes
Tribunal penalties: suspension of disbelief
In the June issue of Tax Adviser, I reported on the Cooke case (‘Two DP or not two DP, that’s the problem’), where an in...
HMRC’s Interest Review Unit: claims for interest mitigation
Speak to most tax advisers or accountants who interact with HMRC on a regular basis and they will be able to provide num...
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Carvajal v HMRC: attempts to mitigate inheritance tax
Without wishing to comment on the accuracy of the general public’s perception of inheritance tax, it is probably fair to...
Filing software: should HMRC set more in-depth standards?
One area of increasing importance concerns responsibilities where taxpayers and/or their agents use software to file ret...
The pursuit of costs: litigation processes
A fundamental aspect of the tribunals system is that a tribunal is meant to be a more accessible forum for achieving jus...
Making Tax Digital for Income Tax: looking forwards
The start date of Making Tax Digital for Income Tax (MTD ITSA) was officially deferred from 6 April 2024 to 6 April 2026...
The case of Cooke v HMRC: the problems caused by a rounding error
Entrepreneurs’ relief (now business asset disposal relief) was introduced in the Finance Act 2008 and has survived longe...
Good guidance: one year on from LITRG’s report
The CIOT’s Low Incomes Tax Reform Group (LITRG) published a report in April 2023 – ‘Good guidance: the importance of eff...
Capital interests: mixed member partnerships
In January, the First-tier Tribunal handed down its decision in Boston Consulting Group UK LLP and others v HMRC [2024] ...