.png)
.png)
PETE MILLER considers the messages that can be decoded from two recent cases concerning HMRC powers
KEY POINTS
- HMRC obtained search warrants in an ex parte hearing.
- Warrants are quashed on appeal as unlawful.
- The importance of correct implementation of schemes.
- Is a dividend right a ‘financial product’?
- The relevance of counsel’s opinion to penalty charges.
Mercury Tax Group has been in the tax news recently having been successful in two cases against HMRC where the department’s use of administrative powers was challenged.
One case concerned HMRC’s use of powers to enter and search properties while the other was about penalties under the disclosure of tax avoidance schemes (DoTAS) rules.
Both cases are useful demonstrations of the checks and balances within the system and particularly in respect of the first case will be at least as important under the new HMRC powers regime – introduced with...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
