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Tooth and claw?: The meaning of words in tax assessments
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.
Read moreV@ Update – September 2021
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.
Read moreHMRC issues 'nudge' letters to non-doms for suspected unpaid tax
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.
Read moreAccountants obliged to report suspected misuse of the Bounce Back Loan Scheme
The Bounce Back Loan Scheme (BBLS) was introduced to enable smaller businesses adversely affected by the coronavirus pandemic to access government-backed finance.
Read moreTax Bites - September 2021
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ Update – August 2021
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.
Read moreCustoms and excise quarterly - August 2021
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.
Read moreTax Bites - August 2021
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreCorporate Tax Update - July 2021
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 and June 2021. Included in this update are news of the historic G7 agreement as to plans for global tax reform, summaries of two cases on the required formalities for bringing contractual claims for breach of warranty and pursuant to a tax covenant, and news of another win for HMRC in an ‘IR35’ case. As ever we hope you, your family and friends are all staying safe and are enjoying the summer.
Read moreV@ update - July 2021
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.
Read moreTax Bites - July 2021
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - June 2021
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.
Read moreTax Bites - June 2021
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - May 2021
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.
Read moreTax Bites - May 2021
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreDisputes Yearbook 2021: Criminal tax disputes
As part of the acclaimed Disputes Yearbook, Legal Business interviewed members of our disputes team exploring key areas of the market and what RPC brings to the table.
Read moreV@ update - April 2021
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.
Read moreTax Bites - April 2021
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - March 2021
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 moreHMRC Crackdown on Covid-19 Fraud
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 moreTax Bites - March 2021
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - February 2021
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 moreCustoms and excise quarterly - February 2021
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 moreTax Bites - February 2021
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - January 2021
Welcome to the January 2021 edition of RPC's V@, an update on developments in the VAT world that may impact your business.
Read moreCorporate Tax Update - January 2021
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 December 2020. Included in this update are summaries of an unexpected twist in the DAC6 saga, a call for evidence on VAT and the ‘sharing economy’, and the Court of Appeal decision in the Development Securities case. As ever we hope you, your family and friends are all staying safe.
Read moreContentious tax: quarterly review
HMRC is increasingly targeting multinationals, in particular by questioning their transfer pricing arrangements and ensuring that they are not artificially diverting profits away from the UK. Additionally, HMRC has made a number of arrests and begun criminal investigations in relation to suspected fraud concerning the coronavirus job retention scheme.
Read moreTax Bites - December 2020
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - November 2020
Welcome to the November 2020 edition of RPC's V@, an update on developments in the VAT world that may impact your business.
Read moreCustoms and excise quarterly - November 2020
In this update we report on (1) import duty and VAT when importing decorations and awards; (2) the moving of excise goods under the Northern Ireland Protocol; and (3) an HMRC Tax Importation and Impact Note in relation to the new Customs (Bulk Customs Declaration and Miscellaneous Amendments) (EU Exit) Regulations 2020.
Read moreTax Bites - November 2020
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - October 2020
Welcome to the October 2020 edition of RPC's V@, an update on developments in the VAT world that may impact your business.
Read moreCorporate Tax Update - October 2020
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 September 2020. Included in this update are summaries of the Chancellor’s tax announcements as part of the Winter Economy Plan and the EC’s decision to appeal the decision of the European General Court in the Apple state aid case. There are also updates on new HMRC guidance on off-payroll working for private businesses and the VAT treatment of payments for early termination of contracts. As ever we hope you, your family and friends are all staying safe.
Read moreTax Bites - October 2020
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - September 2020
Welcome to the September 2020 edition of RPC's V@, an update on developments in the VAT world that may impact your business.
Read moreTax Bites - September 2020
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - August 2020
Welcome to the August 2020 edition of RPC's V@, an update on developments in the VAT world that may impact your business.
Read moreCustoms and excise quarterly update - August 2020
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 moreTax Bites - August 2020
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreV@ update - July 2020
Welcome to RPC's V@, a monthly update on developments in the VAT world that may impact your business.
Read moreCorporate Tax update - July 2020
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 moreTax Bites - July 2020
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreCorporate tax update - June 2020
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 moreV@ update - May 2020
Welcome to the first edition of RPC's V@, an update on developments in the VAT world that may impact your business.
Read moreTax Bites - June 2020
Welcome to the latest edition of RPC's Tax Bites - providing monthly bite-sized updates from the tax world.
Read moreCustoms and excise quarterly update May 2020
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 moreCorporate tax update - May 2020
Welcome to the latest edition of our corporate tax update, written by members of RPC's tax team. This month's update reports on the key developments from April 2020. April was not a “bumper” month for corporate tax developments but (as you would expect) there have been some Covid-19 related developments of note. This month's report also includes a summary of the Supreme Court's decision in Zipvit (on input VAT recovery). We hope you, your family and friends are all staying safe
Read moreTax Bites - May 2020
Welcome to the first edition of RPC's Tax Bites providing monthly bitesized updates from the tax world.
Read moreVAT update - April 2020
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 moreTax update - April 2020
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.
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