RPC Tax Take

For tax professionals on the move

Tax tribunal criticises HMRC's guidance in Catherine Rawcliffe v HMRC

Posted on May 22, 2013 by Ebrahim Ali

This case1 is of interest not so much for the underlying legal issue which was determined but rather for the unusually strong criticism from the First-tier Tribunal ('FTT') of HMRC's published guidance on approved company securities option plans. Facts The taxpayer, who was employed by ACI Ltd, wa... read more

Goldman Sachs – the plot thickens!

Posted on May 15, 2013 by Jonathan Levy

Retired but not gone away Readers of our blog will be familiar with the controversy surrounding the now retired Dave Hartnett, former Permanent Secretary for Tax at HMRC (see postings of 19 December 2011 and 21 December 2011). Readers will recall that the Public Accounts Committee ('PAC') issued a ... read more

Termination payments: don't forget the breakdown

Posted on May 08, 2013 by Daniel Wyatt

In an encouraging win for taxpayers, the First-tier Tribunal ('FTT') in Johnson v HMRC1 allowed an appeal relating to a termination payment under a compromise agreement. It did so notwithstanding its decision in Reid v HMRC2, a case with similar facts (indeed even involving another director of the s... read more

Tribunal allows VAT appeal and accepts that letter was sent to HMRC

Posted on May 01, 2013 by Adam Craggs

The First-tier Tribunal ('FTT') has allowed the taxpayer's appeal in Exeter Estates Ltd v HMRC1 against a decision of HMRC that it had opted to tax all the land and buildings on one of its sites. The facts In 2007, the taxpayer purchased a site consisting of land and buildings (the 'Site'). On 18 ... read more

Tribunal rejects purposive interpretation and allows taxpayer's appeal

Posted on April 26, 2013 by Nigel Brook

The First-tier Tribunal ('FTT') has held in Fidex Ltd v HMRC,1 that a loan relationship debit should not be disallowed under paragraph 13, Schedule 9, Finance Act 1996 ('Paragraph 13'),2 even though one of the main purposes of entering into the arrangement was tax avoidance. The facts In preparing... read more

SDLT mitigation arrangement fails before the Tax Tribunal

Posted on April 22, 2013 by Jonathan Levy

The First-tier Tribunal ('FTT') has dismissed the taxpayer's appeal in Edward Allchin v HMRC.[1] Mr Allchin utilised a stamp duty land tax ('SDLT') mitigation arrangement which was intended to engage section 45 Finance Act 2003, and thereby provide sub-sale relief. HMRC did not accept that the ar... read more

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Civil Guidance

Appealing to the Upper Tribunal

Civil Tax Appeals

Funding tax litigation

Criminal Guidance

Confiscation orders

Restraint proceedings

The role of the forensic accountant

What happens during a criminal prosecution and at trial

Interviews under caution

The Role of the Solicitor at the Police Station

Arrest and what happens next

Dawn raids’ and risk management

HMRC’s Criminal Powers

Who investigates tax fraud and who prosecutes it?

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 Jonathan Levy or Adam Craggs .