Latest by Adam Craggs

Publication

Financial Crime Time – Your Update from RPC: 2021 Q1

Published on 12 April 2021. By Adam Craggs, Partner and Michelle Sloane, Partner and Alice Kemp, Senior Associate

Green tint 3

Welcome to the latest edition of our round-up of news making the headlines in the world of financial crime and compliance. Our aim is to give you an easily digestible, bite-sized overview of issues that may affect your business.

Read more
Publication

Tax Bites - April 2021

Published on 01 April 2021. By Adam Craggs, Partner and Harry Smith, Senior Associate

Purple tint

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

Read more
Publication

V@ update - March 2021

Published on 25 March 2021. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Purple tint

Welcome to the March 2021 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.

Read more
Publication

Spotlight on private wealth - March 2021

Published on 25 March 2021. By Adam Craggs, Partner and Geraldine Elliott, Global Head of Commercial Disputes and Davina Given, Partner and Emma West, Senior Associate

Untinted 5

Our quarterly update is designed to keep you up to speed with developments in the private wealth world.

Read more
Blog

The long arm of HMRC

Published on 24 March 2021. By Adam Craggs, Partner and Alice Kemp, Senior Associate

Gray tint 3

Adam Craggs and Alice Kemp outline the powers HMRC has at its disposal when conducting a criminal rather than civil investigation.

Read more
Publication

HMRC Crackdown on Covid-19 Fraud

Published on 05 March 2021. By Adam Craggs, Partner and Michelle Sloane, Partner and Alice Kemp, Senior Associate

Green tint 2

In the March 2021 Budget, Chancellor Rishi Sunak announced the creation of a new major fraud taskforce, the Taxpayer Protection Taskforce, established as part of a wide-reaching crackdown on criminals exploiting UK government support schemes. The new taskforce represents one of the all-time largest responses to a fraud risk by HMRC.

Read more
Publication

Tax Bites - March 2021

Published on 04 March 2021. By Adam Craggs, Partner and Harry Smith, Senior Associate

Purple tint

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

Read more
Publication

V@ update - February 2021

Published on 25 February 2021. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Gray tint 3

Welcome to the February 2021 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.

Read more
Publication

Customs and excise quarterly - February 2021

Published on 23 February 2021. By Adam Craggs, Partner

Purple tint 2

In this update we report on (1) HMRC's proposed new powers to combat illicit tobacco trading; (2) a policy paper setting out how the temporary and pre-lodgement models will operate to control goods coming from the EU to Great Britain; and (3) HMRC Guidance that can be used to check whether a business holds Authorised Economic Operator status.

Read more
Publication

Tax Bites - February 2021

Published on 04 February 2021. By Adam Craggs, Partner and Harry Smith, Senior Associate

Purple tint

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

Read more
Publication

V@ update - January 2021

Published on 28 January 2021. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Purple tint 3

Welcome to the January 2021 edition of RPC's V@, an update on developments in the VAT world that may impact your business.

Read more
Publication

Spotlight on private wealth - December 2020

Published on 14 December 2020. By Adam Craggs, Partner and Geraldine Elliott, Global Head of Commercial Disputes and Davina Given, Partner and Emma West, Senior Associate

Untinted 5

Our quarterly update is designed to keep you up to speed with developments in the private wealth world.

Read more
Publication

Tax Bites - December 2020

Published on 03 December 2020. By Adam Craggs, Partner and Harry Smith, Senior Associate

Purple tint

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

Read more
Publication

V@ update - November 2020

Published on 26 November 2020. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Purple tint 3

Welcome to the November 2020 edition of RPC's V@, an update on developments in the VAT world that may impact your business.

Read more
Blog

HMRC issues nudge letters targeting residence and domicile

Published on 16 November 2020. By Harry Smith, Senior Associate and Adam Craggs, Partner

Green tint 1

In an extension of its 'nudge' letters campaign, HMRC is writing to wealthy taxpayers encouraging them to bring their tax affairs into line.

Read more
Publication

Tax Bites - November 2020

Published on 05 November 2020. By Adam Craggs, Partner and Harry Smith, Senior Associate

Purple tint

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

Read more
Blog

Jurisdiction and the Rule of Law

Published on 04 November 2020. By Adam Craggs, Partner and Robert Waterson, Partner and Constantine Christofi, Senior Associate

Untinted 4

In R (oao Boulting & Anor) v HMRC [2020] EWHC 2207 (Admin), the High Court refused permission to bring a judicial review claim against HMRC, on the basis that the taxpayer had an 'alternative remedy'.

Read more
Publication

V@ update - October 2020

Published on 29 October 2020. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Green tint 3

Welcome to the October 2020 edition of RPC's V@, an update on developments in the VAT world that may impact your business.

Read more
Publication

Tax Bites - October 2020

Published on 01 October 2020. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

Green tint 1

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

Read more
Blog

Contentious tax: quarterly review - September 2020

Published on 29 September 2020. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

Purple tint

The increased flow of information and data to HMRC under the common reporting standard (CRS) has prompted a flurry of so-called ‘nudge’ letters to be issued by HMRC to taxpayers whose offshore affairs it considers may not be in order.

Read more
Blog

HMRC to gain further information gathering powers

Published on 25 September 2020. By Adam Craggs, Partner and Alexis Armitage, Associate

Gray tint 1

Draft legislation, published as part of Finance Bill 2020/21, will, if enacted, grant HMRC the power to issue 'Financial Institution Notices', requiring certain financial institutions to disclose information they hold about certain taxpayer(s) and their assets, without the safeguards which are currently in place.

Read more
Publication

V@ update - September 2020

Published on 25 September 2020. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Green tint 3

Welcome to the September 2020 edition of RPC's V@, an update on developments in the VAT world that may impact your business.

Read more
Publication

Spotlight on private wealth - September 2020

Published on 14 September 2020. By Adam Craggs, Partner and Geraldine Elliott, Global Head of Commercial Disputes and Davina Given, Partner and Emma West, Senior Associate

Untinted 5

Our quarterly update is designed to keep you up to speed with developments in the private wealth world.

Read more
Publication

Tax Bites - September 2020

Published on 03 September 2020. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

Green tint 1

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

Read more
Publication

V@ update - August 2020

Published on 27 August 2020. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Gray tint 5

Welcome to the August 2020 edition of RPC's V@, an update on developments in the VAT world that may impact your business.

Read more
Publication

Customs and excise quarterly update - August 2020

Published on 25 August 2020. By Adam Craggs, Partner and Michelle Sloane, Partner

Green tint 1

In this update we report on (1) the government's guidance concerning border planning for the end of the transition period; (2) the government's plans to support customs intermediaries; and (3) the government's recently published policy papers on moving goods under the Northern Ireland Protocol, following the transition period. We also comment on three cases relating to (1) whether UK acquisition VAT can apply when a bonded warehouse is not located in the UK; (2) the clarification of factors HMRC can use to determine whether a person is 'fit and proper' to carry out a controlled activity; and (3) whether an acquittal of a criminal charge can preclude HMRC from issuing an excise duty assessment.

Read more
Publication

Tax Bites - August 2020

Published on 06 August 2020. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

Green tint 2

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

Read more
Publication

V@ update - July 2020

Published on 30 July 2020. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Untinted 4

Welcome to RPC's V@, a monthly update on developments in the VAT world that may impact your business.

Read more
Publication

Corporate Tax update - July 2020

Published on 29 July 2020. By Ben Roberts, Partner and Adam Craggs, Partner and Robert Waterson, Partner

Gray tint 1

Welcome to the latest edition of our Corporate Tax Update, written by members of RPC’s tax team. This month’s update reports on some of the key developments from June 2020. Included in this update are a summary of a decision on the correct tax treatment of bonuses paid to members of an LLP, and an AG’s opinion on the VAT reverse charge position of services supplied for non-economic activity purposes. There’s also an update on HMRC guidance on “exceptional” circumstances in which anticipated losses can be used to claim back overpaid corporation tax. Finally, this update also reports on Covid-19 driven extensions to DAC6 reporting deadlines and to deadlines for notifying VAT options to tax. As ever we hope you, your family and friends are all staying safe.

Read more
Publication

Tax Bites - July 2020

Published on 02 July 2020. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

Gray tint 1

Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.

Read more
Publication

Corporate tax update - June 2020

Published on 26 June 2020. By Ben Roberts, Partner and Adam Craggs, Partner and Robert Waterson, Partner

Green tint 3

Welcome to the latest edition of our corporate tax update, written by members of RPC’s tax team. This month’s update reports on some of the key developments from May 2020. As well as some further COVID-19 related tax developments, this month’s report also has a bit of a sports theme with summaries of decisions involving an ex-England cricket captain and football referees. As ever we hope you, your family and friends are all staying safe.

Read more
Publication

V@ update - June 2020

Published on 26 June 2020. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Gray tint 1

Welcome to RPC's V@, a monthly update on developments in the VAT world that may impact your business. In this month’s update we report on (1) VAT treatment on fixed odds betting terminals and gaming machines; (2) VAT treatment of property search fees charged by solicitors and conveyancers; and (3) domestic reverse charge VAT for construction services ­delay in implementation.

Read more
Blog

Partners and closure notices: making amends

Published on 10 June 2020. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

Untinted 3

In R (on the application of Amrolia) v HMRC; R (on the application of Ranjit-Singh) v HMRC [2020] EWCA Civ 488, the Court of Appeal held that notices amending individual partners’ tax returns under section 28B(4), Taxes Management Act 1970 (TMA), were not closure notices and therefore did not need to specify the final amounts of tax due.

Read more
Publication

Customs and excise quarterly update May 2020

Published on 26 May 2020. By Adam Craggs, Partner and Michelle Sloane, Partner

Gray tint 1

In this update we report on (1) temporary changes to customs authorisations during the coronavirus outbreak; (2) the government's plans to introduce 10 new freeports; and (3) a new liability for carrying out an operation or dilution on wine. We also comment on three recent cases relating to (1) refusal of permission to appeal an excise duty assessment out of time; (2) the customs classification of mobility scooters; and (3) liability to pay excise duty in relation to the movement of dutiable goods under a suspension regime.

Read more
Blog

Henkes – FTT has jurisdiction to determine mixed questions of fact and law on application for closure notice

Published on 20 May 2020. By Adam Craggs, Partner

Green tint 2

In Henkes v HMRC [2020] UKFTT 159 (TC), the First-tier Tribunal (FTT) decided that it has jurisdiction to determine mixed questions of fact and law on an application for a closure notice and appeal against an information notice.

Read more
Publication

VAT update - April 2020

Published on 30 April 2020. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Gray tint 1

In this month’s update we report on (1) the Value Added Tax (Finance) Order 2020 (SI 2020/209), which amends the fund management exemption; (2) HMRC’s guidance on the deferral of VAT payments due to COVID-19; and (3) HMRC’s guidance on how importers can pay no import duty and VAT on medical supplies, equipment and protective garments.

Read more
Blog

COVID-19 – Now is not the time for businesses to be complacent

Published on 16 April 2020. By Adam Craggs, Partner and Alice Kemp, Senior Associate

Green tint 1

On 31 March 2020, the Crown Prosecution Service (CPS) and National Police Chiefs' Council (NPCC) issued guidance(1) on how investigators and prosecutors are proposing to tackle the issuing of new criminal proceedings during 'an unprecedented crisis for the Criminal Justice System in the UK.

Read more
Blog

Fisher – TOAA rules not applicable to sale of business from a UK company to a Gibraltar company

Published on 08 April 2020. By Adam Craggs, Partner

Abstract building

In S Fisher and Others v HMRC [2020] UKUT 62 (TCC), the Upper Tribunal (UT) allowed the taxpayers' appeals and held that the transfer of assets abroad rules did not apply to the sale of a business from a UK company to a Gibraltar company, which was under the control of the same directors and shareholders.

Read more
Publication

Spotlight on private wealth - April 2020

Published on 02 April 2020. By Adam Craggs, Partner and Geraldine Elliott, Global Head of Commercial Disputes and Davina Given, Partner and Emma West, Senior Associate

Purple tint 2

Our quarterly update is designed to keep you up to speed with developments in the private wealth world. In this edition we explore sham trusts, heritage property and removing trustees. We also keep pace with the latest developments in the art sector. If you have any feedback on this update or would like to know more about the issues covered, or anything else, get in touch.

Read more
Publication

Tax update - April 2020

Published on 02 April 2020. By Adam Craggs, Partner

Gray tint 2

In this month’s update we report on (1) HMRC’s updated guidance on certain arrangements which purport to avoid the ‘managed services companies’ legislation; (2) recently published draft legislation on voluntary restitution in the context of the loan charge; and (3) the Government’s decision to suspend the extension of IR35 to the private sector.

Read more
Publication

VAT update - March 2020

Published on 26 March 2020. By Adam Craggs, Partner and Rebekka Sandwell, Associate

Green tint 2

In this month’s update we report on (1) HMRC’s recently published policy paper in relation to the VAT liability of digital publications; (2) EU Council Regulation (EU) 2020/283 and Council Directive (EU) 2020/284 in relation to combatting VAT fraud; and (3) EU Council Directive (EU) 2020/285 in relation to the special scheme for small enterprises. We also comment on three recent cases which consider (1) whether a specific form is required for the notification of an assessment of VAT; (2) when VAT is collectable as a debt due; and (3) what constitutes a reasonable excuse for incorrectly issuing a zero-rating VAT certificate.

Read more
Blog

Contentious tax quarterly review (Q4 2019)

Published on 16 December 2019. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

Untinted 5

In this quarterly review we consider: HMRC’s increasing propensity to seek to strike out the taxpayer’s case; recent developments in relation to IR35; the timing of tribunal decisions; and the potential implications of the Inverclyde decision.

Read more
Blog

Locke – Court of Appeal quashes follower and accelerated payment notices

Published on 04 December 2019. By Adam Craggs, Partner

Green tint 1

In R (on the application of Locke) v HMRC [2019] EWCA Civ 1909, the Court of Appeal quashed follower and accelerated payment notices issued to a participant in a film finance partnership, because HMRC had been wrong in considering that a judicial ruling was relevant to the arrangements under consideration.

Read more
Blog

JJ Management: No need to stand on formalities

Published on 09 October 2019. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

Untinted 5

It would appear from the decision of the High Court in R (oao JJ Management LLP and Ors) v HMRC [2019] EWHC 2006 (Admin), that HMRC can conduct informal enquiries outside of section 9A, Taxes Management 1970 (TMA).

Read more
Publication

Tax update October 2019

Published on 03 October 2019. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

Purple tint 5

In this month’s update we report on (1) the independent review of the disguised remuneration loan charge; (2) HMRC’s guidance on preparing for the off-payroll working changes which come into effect from April 2020; and (3) HMRC’s updated guidance on the tax registration of non-resident companies. We also comment on three recent cases relating to (1) an application for final and partial closure notices; (2) the validity of an enquiry; and (3) pre-entry loss rules.

Read more
Publication

Corporate tax update September 2019

Published on 30 September 2019. By Ben Roberts, Partner and Adam Craggs, Partner and Robert Waterson, Partner

Untinted 4

This month’s update reports on the key developments from August 2019. Although this was a relatively quiet month in the corporate tax world, this update includes summaries of an important Upper Tribunal decision on the correct tax treatment of “trail commissions” and a First-tier Tribunal decision on the recovery of pre-incorporation input VAT.

Read more
Publication

VAT update September 2019

Published on 26 September 2019. By Adam Craggs, Partner

Untinted 3

In this month’s update we report on (1) changes to the reduced rate for energy-saving materials; (2) the VAT rule changes for higher education; and (3) new regulations amending the rules on when VAT adjustments may be made following a change to the price of goods and services. We also comment on three recent cases relating to (1) the refusal of a claim for the repayment of under-recovered input VAT; (2) the repayment of input VAT charged on the acquisition of single farm payment entitlement units; and (3) a notice of security issued with no explanation for the demand.

Read more
Blog

Contentious tax: quarterly review (Q3 2019)

Published on 20 September 2019. By Adam Craggs, Partner and Michelle Sloane, Partner

Untinted 4

In this quarterly review, Adam Craggs and Michelle Sloane consider HMRC’s increasing propensity to seek the production of documents from accountants and other professional advisers, HMRC’s new policy of challenging taxpayers’ loan relationships, and the increase in the number of domicile enquiries launched by HMRC.

Read more
Blog

ANO - pre-ordained transactions avoided CGT losses being caught by pre-entry loss rules

Published on 05 August 2019. By Adam Craggs, Partner

Purple tint 2

In ANO (No1) Limited v HMRC [2019] UKFTT 406 (TC), the First-tier Tribunal (FTT) has held that a pre-ordained series of transactions implemented to avoid the application of Schedule 7A, Taxation of Chargeable Gains Act 1992 (TCGA) to pre-entry losses were effective.

Read more
Blog

Corrado – Tribunal cancels follower notice penalties 

Published on 31 July 2019. By Adam Craggs, Partner

Purple tint 1

In Giulio Corrado v HMRC [2019] UKFTT 275 (TC), the First-tier Tribunal (FTT) has set aside a follower notice penalty as the taxpayer's failure to take corrective action in response to a follower notice was reasonable in all the circumstances.

Read more