Management of taxes
Asymmetric information
One of the key topics for tax administrations concerns what academics might call asymmetric information....
Perils of an unauthorised payment
The taxation of pension schemes was thoroughly overhauled in the Finance Act 2004 with the new rules coming into force o...
No magic money tree
As the world returns, gradually, to full time business on the other side of the Coronavirus pandemic and discovers the ‘...
The role of agents
I set out in my appearance at the Treasury Select Committee at the start of April how HMRC is playing a vital role to de...
A legislative flood
An ever increasing deluge of ink on the statute books is dedicated to quashing any perceived tax avoidance before it eve...
Partners in tax
As I noted in my January 2020 article ‘What a carry-back!’, there remain a number of unresolved questions concerning the...
A deliberate Cliff hanger
In 2019, we saw a number of cases directly addressing the culpability of taxpayers and, in particular, the meaning of de...
An officer and an automaton
Over the past few years, doubts have been raised about whether the Taxes Management Act (TMA) 1970 has kept up with HMRC...
Penalty shootout
The legislative framework for penalties was intended to provide fixed parameters so that penalties became more standard ...