Return of the naïve
The facts of the case In May 2008, the taxpayer (‘Mr Hardy’) entered into a contract to purchase a leasehold property, ...
Management of taxes
Management of taxes
In the cloud
The use of technology has become a prerequisite for success in almost every sector of business.
Pro-holy and pro-Fane
One of the novelties of the penalty provisions found in FA 2007, Sch 24 (penalties for inaccurate tax returns etc) is th...
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Latest briefings
Who will dare to design, market or facilitate tax avoidance arrangements?
The publication by HMRC of the consultation document on 17 August 2016 setting out new sanctions for those who design, m...
Sticks without Carrots - The Worldwide Disclosure Facility and the Requirement to Correct
Anyone who is asked to write about the Worldwide Disclosure Facility (or ‘WDF’) soon finds themselves musing on the mean...
Why the CIOT?
The CIOT sub-committees perform a significant role in responding to technical developments: in particular to the myriad ...
Building blocks
One of the fundamental building blocks of the European Treaties is the concept of state aid.
Global transparency
Of all the measures to emerge from the OECD/G20’s Base Erosion and Profit Shifting (BEPS) Project, the one that has had ...
A harsher environment
HMRC and the Treasury continue to take action against tax avoidance arrangements (TAAs) as political and public opinion ...
Jigsaw puzzle
In my article ‘La Peine Quotidienne’, Tax Adviser, February 2015, I discussed the penalty rules for late tax returns, as...