Latest by Adam Craggs

Publication

Tax Bites - August 2022

Published on 04 August 2022. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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

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Publication

HMRC investigating hundreds of UK customers of Puerto Rico-based Euro Pacific Bank

Published on 29 July 2022. By Adam Craggs, Partner and Alice Kemp, Senior Associate (Employed Barrister)

HMRC investigating hundreds of UK customers of Puerto Rico-based Euro Pacific Bank.

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Publication

V@ update - July 2022

Published on 28 July 2022. By Adam Craggs, Partner and Harry Smith, Senior Associate

Welcome to the July 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.

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Publication

Spotlight on Private Wealth - July 2022

Published on 14 July 2022. By Adam Craggs, Partner and Geraldine Elliott, Global Head of Commercial Disputes

Welcome to Spotlight on Private Wealth. This update is designed to keep you up to speed with developments in the private wealth world. In this edition we explore everything from tax gifts to the meaning of knowledge.

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Publication

Tax Bites - July 2022

Published on 07 July 2022. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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

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Publication

All is not (necessarily) lost: Crypto crime recovery

Published on 30 June 2022. By Adam Craggs, Partner and Alice Kemp, Senior Associate (Employed Barrister)

With over 2 million people in the UK now holding and using cryptocurrency, and the Chancellor announcing that a government backed non-fungible token ("NFT") is to be issued by the Royal Mint this summer, the market for crypto-assets is expected to continue to grow in the coming months and years; so much so that legislation is planned to implement a new regulatory regime for the crypto market.

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Publication

V@ update - June 2022

Published on 30 June 2022. By Adam Craggs, Partner and Harry Smith, Senior Associate

Welcome to the June 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.

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Publication

Non-compliance with CrimPR does not render otherwise timely information a nullity

Published on 28 June 2022. By Adam Craggs, Partner

The Court confirmed that, while offences must be charged within any applicable time limit for charging, the requirement that the charge must contain "such particulars of the conduct constituting the commission of the offence as to make clear what the prosecutor alleges against the defendant", in Criminal Procedure Rule (CrimPR) Rule 7.3(1)(b), did not require a statement from the prosecutor that the offence had been laid within the relevant time limit if the timing of the offence was not an element specified in the offence.

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Blog

Tax Tribunal cancels discovery assessments and late filing penalties

Published on 22 June 2022. By Adam Craggs, Partner

In Robert Don Hunter Dougan v HMRC [2022] UKFTT 00140 (TC), the First-tier Tribunal (FTT) cancelled certain discovery assessments issued to a taxpayer by HMRC, on the basis they were issued out of time because the taxpayer's behaviour was careless rather than deliberate, for the purposes of section 36, Taxes Management Act 1970 (TMA). The FTT also cancelled various late filing penalties and late payment surcharges issued by HMRC, on the basis the notices were not validly served on the taxpayer.

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Publication

Financial Crime Time - Your update from RPC: 2022 Q2

Published on 14 June 2022. By Adam Craggs, Partner and Michelle Sloane, Partner and Alice Kemp, Senior Associate (Employed Barrister)

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.

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Publication

Tax Bites - June 2022

Published on 09 June 2022. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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

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Publication

V@ update - May 2022

Published on 26 May 2022. By Adam Craggs, Partner

Welcome to the May 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.

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Publication

Customs and excise quarterly update - May 2022

Published on 24 May 2022. By Adam Craggs, Partner and Michelle Sloane, Partner

Welcome to the May 2022 edition of RPC's Customs and Excise Quarterly Update. In order to enhance your reading experience, we have adapted the format. We hope you like it

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Blog

HMRC's civil and criminal powers

Published on 19 May 2022. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

HMRC has been provided with extensive and wide-ranging powers, which have increased exponentially in recent years. This article considers HMRC’s main investigatory and assessment powers, by reference to its general enquiries, as well as specific/aspect enquiries, including criminal investigations.

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Publication

Tax Bites - May 2022

Published on 05 May 2022. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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

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Publication

V@ update - April 2022

Published on 28 April 2022. By Adam Craggs, Partner

Welcome to the April 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.

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Publication

Tax Bites - April 2022

Published on 07 April 2022. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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

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Publication

V@ update - March 2022

Published on 31 March 2022. By Adam Craggs, Partner

Welcome to the March 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.

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Publication

Financial Crime Time - Your update from RPC: 2022 Q1

Published on 30 March 2022. By Adam Craggs, Partner and Michelle Sloane, Partner and Alice Kemp, Senior Associate (Employed Barrister)

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.

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Publication

Tax Bites - March 2022

Published on 03 March 2022. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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

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Publication

V@ update - February 2022

Published on 24 February 2022. By Adam Craggs, Partner

Welcome to the February 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.

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Publication

Customs and excise quarterly update - February 2022

Published on 22 February 2022. By Adam Craggs, Partner and Michelle Sloane, Partner

In this update we report on (1) a new customs consultation launched by the government; (2) HMRC's updated guidance on pre-clearance checks; and (3) stage three of Brexit customs changes. We also comment on three recent cases relating to (1) HMRC's failure to issue assessment notices within the statutory timeframe for excise duty; (2) the customs classification of the Rough Terrain Vehicle X900; and (3) the customs classification of certain TV stands.

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Publication

Spotlight on Private Wealth - February 2022

Published on 22 February 2022. By Adam Craggs, Partner and Geraldine Elliott, Global Head of Commercial Disputes

Welcome to Spotlight on Private Wealth. This update is designed to keep you up to speed with developments in the private wealth world. In this edition we explore everything from Royal wills to cryptocurrency.

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Publication

Tax Bites - February 2022

Published on 03 February 2022. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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

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Publication

V@ Update – January 2022

Published on 27 January 2022. By Adam Craggs, Partner

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Welcome to the January 2022 edition of RPC's V@, an update which provides analysis and news from the VAT world relevant to your business.

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Blog

Quarterly Contentious Tax Review – Winter 2021

Published on 22 December 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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HMRC has extensive powers to require information and documentation from taxpayers. These powers were bolstered in the last Finance Act to include financial institution notices. Failure to comply with information notices can attract penalties. The most severe penalties are those imposed by the Upper Tribunal (UT). We examine, below, HMRC's increasing use of these powers, together with HMRC's penchant for 'nudge' letters and recent developments in the application of the transfer of assets abroad (TOAA) provisions.

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Publication

Financial Crime Time - Your update from RPC: 2021 Q4

Published on 13 December 2021. By Adam Craggs, Partner and Michelle Sloane, Partner and Alice Kemp, Senior Associate (Employed Barrister)

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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.

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Publication

Tax Bites - December 2021

Published on 02 December 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world. As always, if there are any areas you would like more information on (or if you have any questions or feedback), please let us know or get in touch with your usual RPC contact.

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Publication

Customs and excise quarterly update - November 2021

Published on 30 November 2021. By Adam Craggs, Partner and Michelle Sloane, Partner

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In this update we report on (1) the revised timetable for border controls on imports from the EU; (2) regulations regarding the new Freeports; and (3) updates to safety and security requirements on imports and exports from the EU. We also comment on three recent cases relating to (1) time limits and procedural requirements in a customs context; (2) whether UK acquisition VAT can apply when a bonded warehouse is not located in the UK; and (3) the tariff classification of mastectomy bras.

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Publication

V@ Update – November 2021

Published on 25 November 2021. By Adam Craggs, Partner

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

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Publication

Spotlight on Private Wealth - November 2021

Published on 08 November 2021. By Adam Craggs, Partner and Geraldine Elliott, Global Head of Commercial Disputes

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Welcome to Spotlight on Private Wealth. This update is designed to keep you up to speed with developments in the private wealth world. In this edition we explore everything from Royal wills to cryptocurrency.

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Publication

HMRC issues 'nudge' letters to recipients of foreign investment income

Published on 05 November 2021. By Adam Craggs, Partner and Harry Smith, Senior Associate

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HMRC is targeting taxpayers who received foreign investment income in 2019/20, and who, HMRC believes, claimed foreign tax credit relief incorrectly, or at the wrong rates. HMRC has issued 'nudge' letters to taxpayers encouraging them to reconsider their tax position.

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Publication

Tax Bites - November 2021

Published on 04 November 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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

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Publication

V@ Update – October 2021

Published on 28 October 2021. By Adam Craggs, Partner

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

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Publication

HMRC Target Cryptocurrency Investors

Published on 21 October 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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HMRC has announced it will launch a new ‘nudge letter’ campaign that will target UK taxpayers who may have failed to pay tax due in respect of their cryptoassets.

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Publication

Financial Crime Time - Your update from RPC: 2021 Q3

Published on 13 October 2021. By Adam Craggs, Partner and Michelle Sloane, Partner and Alice Kemp, Senior Associate (Employed Barrister)

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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.

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Publication

Tooth and claw?: The meaning of words in tax assessments

Published on 05 October 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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The concept of 'staleness' in the context of discovery assessments (assessments issued to taxpayers by HMRC outside of any statutory enquiry), gathered momentum following the Upper Tribunal’s decision in Charlton and others v HMRC [2011] UKFTT 467 (TC). As 'discovery' is only relevant to returns and tax years where HMRC has not opened a statutory enquiry, many commentators considered that the concept provided a degree of procedural fairness in the discovery assessment process, and that HMRC should not be permitted to delay issuing an assessment for a considerable period of time after making a discovery. As recently as February of this year, Judge Malek in the First-tier Tribunal (FTT) in Mehrban v HMRC [2021] UKFTT 53 (TC), noted that it was an “absurdity” to say that the concept of staleness does not exist.

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Publication

V@ Update – September 2021

Published on 30 September 2021. By Adam Craggs, Partner

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

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Publication

HMRC issues 'nudge' letters to non-doms for suspected unpaid tax

Published on 28 September 2021. By Adam Craggs, Partner and Harry Smith, Senior Associate

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HMRC is targeting wealthy UK tax residents claiming a non-UK domicile who may not have paid the remittance basis charge. HMRC has issued hundreds of 'nudge' letters to taxpayers encouraging them to reconsider their tax position.

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Blog

Eclipse film partnerships settlement opportunity announced by HMRC

Published on 08 September 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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HMRC announced on 6 September 2021 a settlement opportunity for current and former members of the Eclipse Film Partners (numbers 1 to 40) limited liability partnerships (the Eclipse LLPs), under which HMRC will agree not to seek to impose a 'dry tax' charge in exchange for members settling historic tax liabilities (with interest) and abandoning litigation against HMRC in relation to the Eclipse LLPs. If accepted by each taxpayer, approximately £1.6 billion of 'dry tax' will not be pursued by HMRC.

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Publication

Accountants obliged to report suspected misuse of the Bounce Back Loan Scheme

Published on 07 September 2021. By Adam Craggs, Partner and Michelle Sloane, Partner

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The Bounce Back Loan Scheme (BBLS) was introduced to enable smaller businesses adversely affected by the coronavirus pandemic to access government-backed finance.

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Publication

Tax Bites - September 2021

Published on 02 September 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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

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Publication

V@ Update – August 2021

Published on 26 August 2021. By Adam Craggs, Partner

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

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Blog

Contentious tax quarterly review 

Published on 25 August 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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We consider the Supreme Court's decision in Tooth, concerning discovery assessments; and examine the contentious issue of when a taxpayer can rely upon a PAYE credit. We also review the increased focus by HMRC on cryptoassets and the challenges that might create for taxpayers.

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Publication

Customs and excise quarterly - August 2021

Published on 24 August 2021. By Adam Craggs, Partner and Michelle Sloane, Partner

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In this update we report on (1) European Commission Guidance on UK import formalities; (2) HMRC's new and updated guidance for imports and exports following the end of the Brexit transition period; and (3) HMRC's updated guidance on returned goods relief on items exported from Northern Ireland. We also comment on three recent cases relating to (1) the illegal import of cigarettes; (2) customs valuation; and (3) the application of the dishonesty test when determining penalties.

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Blog

Kelly – Tax tribunal confirms re-discovery not permissible for the purposes of section 29 TMA

Published on 10 August 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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In Sean Kelly v HMRC [2021] UKFTT 162, the First-tier Tribunal (FTT) confirmed the principle that a discovery can only be made once and HMRC cannot raise a new discovery assessment under section 29,Taxes Management Act 1970 (TMA), in respect of the same discovery.

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Publication

Tax Bites - August 2021

Published on 05 August 2021. By Adam Craggs, Partner and Harry Smith, Senior Associate

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

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Publication

V@ update - July 2021

Published on 29 July 2021. By Adam Craggs, Partner

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

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Blog

Siddiqui - No proper ground for setting aside summons in private prosecution

Published on 21 July 2021. By Adam Craggs, Partner

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Private prosecution not to be quashed due to failure to disclose settlement agreement.

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Publication

Spotlight on private wealth - July 2021

Published on 12 July 2021. By Adam Craggs, Partner and Geraldine Elliott, Global Head of Commercial Disputes and Davina Given, Partner and Emma West, Senior Associate

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

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