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RPC Tax Take

For tax professionals on the move

FTT decision pays dividends for Mr and Mrs Jones

Posted on January 29, 2015 by Nick Allan
Nick Allan
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In Richard Jones, Julie Jones v HMRC[1], the First-tier Tribunal (Tax Chamber) (FTT) has decided that the owners of an insolvent recruitment consultancy do not have to pay employment taxes in respect of dividends paid to them which they subsequently reclassified as salary.   Background Mr and Mrs... read more

CJEU confirms UK failed to comply with EU law by retroactively curtailing rights of taxpayers to recover tax unlawfully paid

Posted on January 22, 2015 by Nigel Brook
Nigel Brook
Nigel Brook is an Associate at RPC specialising in commercial litigation, conten
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The European Commission has succeeded in obtaining a declaration from the CJEU that the UK Government failed to comply with its obligations, under Article 4(3) of the TEU, by retroactively curtailing the right of taxpayers to recover tax levied contrary to European law.   Background English law p... read more

HMRC Dishonesty Allegation "seriously flawed"

Posted on January 14, 2015 by Kristiana Reynolds
Kristiana Reynolds
Kristiana is a third seat trainee solicitor in RPC's Commercial Disputes team, f
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The First-tier Tribunal (Tax Chamber) ("FTT") has ruled, in Citibank NA v Revenue and Customs Commissioners[1], that HMRC's pleadings were "seriously flawed". When alleging fraud against a taxpayer, HMRC must clearly plead that the taxpayer had a dishonest state of mind.   Background On 27 August... read more

Tribunal sets aside witness summonses due to misrepresentation and failure in duty to make full and frank disclosure to the Tribunal

Posted on January 08, 2015 by Nicholas Fernyhough
Nicholas Fernyhough
Nick Fernyhough is a Senior Associate in RPC's tax dispute resolution team, with
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An interesting decision has recently been issued by the First-tier Tribunal (Tax Chamber) ('FTT') in connection with an application to set aside the issue of witness summonses which had been issued to two individuals who were resident in Jersey[1].   Background Clavis Liberty Fund 1 LP ('the App... read more

2014 – The year that was

Posted on December 16, 2014 by Nigel Brook
Nigel Brook
Nigel Brook is an Associate at RPC specialising in commercial litigation, conten
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  Seasonal greetings to all of our readers!   2014 has been another busy year for the RPC Tax Take team. Continuing a tradition we started last year we are bringing the year to a close with a look back at some of our most popular blog posts from the last 12 months.   Kicking off the year in s... read more

Tribunal adopts a literal interpretation of the provisions in allowing the taxpayer's appeal

Posted on December 11, 2014 by Nick Allan
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In Philip Shirley v HMRC, [1] the First-tier Tribunal (Tax Chamber) (FTT) concluded that a provision in a statute rewritten as part of the Tax Law Rewrite Project should be literally interpreted as the wording in question was clear and unambiguous. Background Philip Shirley (the taxpayer) was res... read more

Appealing to the Upper Tribunal

Civil Tax Appeals

Funding tax litigation

Confiscation orders

Restraint proceedings

The role of the forensic accountant

Interviews under caution

Arrest and what happens next

Dawn raids’ and risk management

HMRC’s Criminal Powers

About this blog

Albert Einstein once remarked, on trying to complete his tax return: "This is too difficult for a mathematician. It takes a philosopher!". As tax practitioners are only too well aware, tax legislation continues to increase in length and complexity with the passing of each Finance Act. There is also a steady stream of new case law. Our hope is that, against this background, RPC Tax Take will be a useful source of current information and comment to busy practitioners. It features regular postings on the latest news and developments in UK tax law, together with a number of practical Practice Notes written by specialist lawyers at RPC.

We welcome comments and feedback – please get in touch!

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We regularly present seminars for leading firms of accountants on topics within our expertise. If you would like to discuss the possibility of our team running a seminar for your firm, please contact Adam Craggs.

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