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RPC Tax Take

For tax professionals on the move

HMRC'S APPLICATION FOR SECURITY FOR COSTS REFUSED

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

Tribunal orders HMRC to pay taxpayer's costs – Ian Elder v HMRC

Posted on November 07, 2014 by Robert Waterson
Robert Waterson
Robert is a senior associate at RPC with 8 years’ experience in direct tax and V
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The decision of the First-tier Tribunal (Tax Chamber) ('FTT') in Ian Elder v Commissioners for HMRC[1] offers a useful summary of the FTT's approach on the assignment of appeals to the Complex category, applications to bar a party from participating in proceeding and costs sanctions. Background T... read more

Tax Tribunal confirms the time period in which HMRC must open an enquiry

Posted on October 30, 2014 by Nicholas Allan
Nicholas Allan
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As readers will be aware, HMRC generally has twelve months from the date a company files a return to open an enquiry[1]. In Dock and Let Ltd v Revenue and Customs Commissioners[2], the First-tier Tribunal (Tax Chamber) ('FTT') had to consider the question of whether that twelve-month period includes... read more

FTT prevents HMRC from having two bites of the cherry!

Posted on October 22, 2014 by Daniel Wyatt
Daniel Wyatt
Daniel Wyatt is an associate at RPC specialising in commercial litigation and ar
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In Lady Henrietta Pearson v HMRC [2014] UKFTT 890 (TC), the First-tier Tribunal (Tax Chamber) ('FTT') concluded that HMRC had "ignored" its previous decision by seeking to reduce the amount of a VAT refund which it had ordered HMRC make to Lady Henrietta Pearson ('the taxpayer'). Background The ta... read more

GMAC's strategy for limiting VAT payments proved lawful in ECJ

Posted on October 16, 2014 by Robert Waterson
Robert Waterson
Robert is a senior associate at RPC with 8 years’ experience in direct tax and V
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The following is taken from an article by Robert Waterson and Nigel Brook, originally published in International Tax Review (12 September 2014). The decision of the ECJ in the GMAC[1] case represents a comprehensive win for the taxpayer. Although many accounts of the decision have focused upon the ... 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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