New remedies
When the OECD’s Base Erosion and Profit-Shifting (BEPS) action plan was announced, Action 14 (making dispute resolution ...
Management of taxes
Management of taxes
Seeking closure
After many years, enquiry closure notices as we know them are on the ‘endangered species’ list as a result of the FB 201...
An easy target
A December 2015 report from the National Audit Office contained the following: ‘HMRC agreed a target to increase the num...
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All’s well that ends badly
In my April 2013 article in Tax Adviser ‘Much Ado about Something’, I wrote about the appeal by JP Whitter (Waterwell En...
Making it public
There’s little doubt that public country-by-country reporting is an emotive topic for tax campaigners....
Directors' meetings
De Beers: the case law test De Beers Consolidated Mines Ltd v Howe (Surveyor of Taxes) 5 TC 198 is often quoted as auth...
Rough seas ahead
Will Brexit impact on the co-operation between HMRC and European tax authorities in cross-border disputes? A notable f...
Basic Instinct
A few years ago, the CIOT/ATT London Branch annual dinner had as its guest speaker Lord Justice Carnwath (now Lord Carnw...
Increasing the burden
HMRC has issued its response to the Government’s public consultation on rules to limit the tax deductions that companies...
A wide view
Background Finance Act 2016 replaced the previous transactions in land (‘TIL’) rules with entirely new legislation, bro...