RPC Tax Take

For tax professionals on the move

Tribunal sets aside HMRC information notice for lack of clarity

Posted on April 23, 2014 by Natalie Drew
Natalie Drew
Natalie is a third seat trainee solicitor in RPC's Commercial Disputes team. Nat
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R D Utilities Ltd v HMRC [2014] UKFTT 303 (TC)   In the recent case of R D Utilities Ltd v HMRC [2014] UKFTT 202 (TC), heard before Judge Alison McKenna, the First–tier Tribunal (Tax Chamber) ('FTT'), set aside an information notice issued by HMRC due to its vague drafting and lack of clarity.  ... read more

HMRC’s computer says no!

Posted on April 16, 2014 by Nigel Brook
Nigel Brook
Nigel Brook is an Associate at RPC specialising in commercial litigation, conten
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In Varma v HMRC [2014] UKFTT 006 (TC), the First-tier Tribunal (Tax Chamber) ('FTT') quashed a penalty that had been issued to a taxpayer for late filing of a self-assessment tax return. This case provides interesting comments on treating taxpayers in a fair and even-handed manner, and the precariou... read more

A lack of goodwill for Medical Professionals

Posted on April 14, 2014 by Guest Bloggers – Abbey Tax
Guest Bloggers – Abbey Tax
Abbey Tax Protection (ATP) provides a variety of tax related products and servic
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Over recent years increasing numbers of medical professionals have sought to incorporate their private practices for perceived tax advantages. By incorporating their private practices the medics have, more often than not, moved from being a sole trader to a limited company, with the sole trade busin... read more

Painting by numbers – Court of Appeal dismisses HMRC's appeal

Posted on April 11, 2014 by Ebrahim Ali
Ebrahim Ali
Ebrahim has been a leading tax disputes lawyer for over 24 years, both at HMRC a
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The Court of Appeal has dismissed HMRC's appeal in Lord Howard of Henderskelfe's Executors v Revenue and Customs Commissioners [2014] EWCA Civ 278 and confirmed that, as the Portrait of Omai by Sir Joshua Reynolds ('the Portrait') was a wasting asset within the meaning of section 44 Taxation of Capi... read more

High Court holds that HMRC's winding up petition should be dismissed as an abuse of process.

Posted on April 03, 2014 by Nicholas Fernyhough
Nicholas Fernyhough
Nick Fernyhough is a Senior Associate in RPC's tax dispute resolution team, with
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The High Court (David Donaldson QC) has held in Enta Technologies Limited v HMRC [2014] EWHC 548 (Ch), that where a winding-up petition was brought by HMRC based on the non-payment of tax raised in assessments and the taxpayer's appeal against those assessments was pending, the winding-up court shou... read more

Tribunal decides that taxpayers must attempt to obtain information held by trustee!

Posted on March 27, 2014 by Natalie Drew
Natalie Drew
Natalie is a third seat trainee solicitor in RPC's Commercial Disputes team. Nat
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In the recent case of H A Patel & K Patel (a partnership) v HMRC [1], the First-tier Tribunal (Tax Chamber) (‘FTT’) dismissed an appeal by the taxpayers that information and documents held by a trustee were not ‘in their possession or power’ for the purpose of paragraph 18, Schedule 36, Finance... 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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