Latest by Adam Craggs

Publication

V@ Update – November 2021

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

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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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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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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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V@ Update – October 2021

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

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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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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 and Rebekka Sandwell, Senior Associate

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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 and Rebekka Sandwell, Senior Associate

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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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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 and Rebekka Sandwell, Senior Associate

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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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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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Publication

Financial Crime Time – Your Update from RPC: 2021 Q2

Published on 06 July 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 - July 2021

Published on 01 July 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 - June 2021

Published on 24 June 2021. By Adam Craggs, Partner and Rebekka Sandwell, Senior Associate

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Welcome to the June 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

Rediscovering ADR

Published on 23 June 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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Alternative Dispute Resolution (ADR), in the form of mediation, remains an important part of the tax dispute resolution process. In light of the backlog of cases caused by Covid-19, and the practice statement issued by the Tribunal last year, we expect that taxpayers and HMRC will begin to re-examine and embrace ADR which can be an effective method of resolving disputes with HMRC.

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Publication

Tax Bites - June 2021

Published on 03 June 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 - May 2021

Published on 27 May 2021. By Adam Craggs, Partner and Rebekka Sandwell, Senior Associate

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Welcome to the May 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

Tax Bites - May 2021

Published on 07 May 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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Blog

Caught in the act

Published on 30 April 2021. By Adam Craggs, Partner and Alice Kemp, Senior Associate (Employed Barrister)

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The furlough scheme has become ‘a magnet for fraudsters’. Adam Craggs and Alice Kemp outline the extensive powers HMRC can muster to investigate ‘high risk’ claims and to claw back any undue payments.

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Contentious tax quarterly review

Published on 30 April 2021. By Adam Craggs, Partner and Constantine Christofi, Senior Associate

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Rise in alternative dispute resolution Until relatively recently, HMRC imposed strict conditions on the timing of when an application for alternative dispute resolution (ADR) could be made, refusing to consider any application which was made after it had formally set out its position in its ‘statement of case’.

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Publication

V@ update - April 2021

Published on 29 April 2021. By Adam Craggs, Partner and Rebekka Sandwell, Senior Associate

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Welcome to the April 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

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 (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 - April 2021

Published on 01 April 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 - March 2021

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

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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.

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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

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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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Blog

The long arm of HMRC

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

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

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HMRC Crackdown on Covid-19 Fraud

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

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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.

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Publication

Tax Bites - March 2021

Published on 04 March 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 - February 2021

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

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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.

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Customs and excise quarterly - February 2021

Published on 23 February 2021. By Adam Craggs, Partner

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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.

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Publication

Tax Bites - February 2021

Published on 04 February 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 - January 2021

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

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

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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

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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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Publication

Tax Bites - December 2020

Published on 03 December 2020. 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 - November 2020

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

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

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Blog

HMRC issues nudge letters targeting residence and domicile

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

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

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Tax Bites - November 2020

Published on 05 November 2020. 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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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

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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'.

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Publication

V@ update - October 2020

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

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

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Publication

Tax Bites - October 2020

Published on 01 October 2020. 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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