RPC Tax Take

For tax professionals on the move

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
User is currently offline

  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
Nick Allan
Guest has not set their biography yet
User is currently offline

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

HMRC's information notice was too vague

Posted on December 04, 2014 by Nigel Brook
Nigel Brook
Nigel Brook is an Associate at RPC specialising in commercial litigation, conten
User is currently offline

This case saw the First-tier Tribunal (Tax Chamber) (FTT) uphold the appeal of the taxpayer against penalties imposed by HMRC for non-compliance with an information notice issued by HMRC pursuant to paragraph 1, Schedule 36, Finance Act 2008 (the Information Notice). The FTT found that the informati... read more

HMRC mislead appellants into believing they have a remedy in the Tribunal in contractual settlement dispute

Posted on November 28, 2014 by Kristiana Reynolds
Kristiana Reynolds
Kristiana is a third seat trainee solicitor in RPC's Commercial Disputes team, f
User is currently offline

In Morris and another v HMRC,[1] the First-tier Tribunal (“the FTT”) has confirmed that it does not have jurisdiction to determine a dispute relating to the correct valuation of assets which were the subject of a contractual settlement with HMRC.   Background Following the death of Mr Sutton in 2... read more


Posted on November 19, 2014 by Nicholas Fernyhough
Nicholas Fernyhough
Nick Fernyhough is a Senior Associate in RPC's tax dispute resolution team, with
User is currently offline

HMRC'S APPLICATION FOR SECURITY FOR COSTS REFUSED - GSM EXPORT (UK) LTD (IN ADMINISTRATION) AND ANOTHER v HMRC[1]   The Upper Tribunal (Judge Berner) has dismissed an application for security for costs made by HMRC in a case which involved an appeal against a refusal of repayment of VAT.   Backg... read more

Applicants for search warrants must make full and frank disclosure to the court

Posted on November 14, 2014 by Adam Craggs
Adam Craggs
Adam heads our market-leading Tax Disputes team and is an accredited mediator. H
User is currently offline

The following is taken from an article by Adam Craggs, originally published in Tax Journal on 31 October 2014.   Introduction Readers may recall that in September 2010, the Chief Secretary to the Treasury, Danny Alexander, announced plans to tackle non-compliance in the tax system over the Spendi... 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!

Seminars for accountants

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.

Subscribe to this blog