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Investigations

European finance ministers have settled the mandate for the European Commission to negotiate stalled tax transparency agreements with countries including Switzerland and Liechtenstein, in a critical step towards confirming the amended Savings Directive and establishing greater levels of automatic tax information exchange in the European Union (EU).

O’Flaherty v CRC, Upper Tribunal (Tax and Chancery Chamber)

HMRC working with overseas counterparts to analyse 400gb of info

HMRC have agreed to change their dealings with represented taxpayers when making corporation tax and income tax checks in the single compliance process (SCP) trial.

A sub-group of the compliance reform forum, which includes representatives from the professional bodies and the Revenue to monitor progress of the SCP pilot, expressed concern about the taxman’s opening approach in the process: to contact the taxpayer directly, even where there was authorisation in place for an agent to act on the taxpayer's behalf.

British overseas territories with significant financial centres have signed up to the government’s strategy to create global tax transparency.

Platform will follow progress of plan against evasion

Figures show major increases in prosecutions and distraint

Overview of HMRC’s latest offshore initiatives against evasion and avoidance

CRC v Sunico A/S and others, Chancery Division

HMRC have added another section to their website’s Spotlights area, which focuses on tax avoidance arrangements the department believes do not work. The latest is, numbered 18, concerns stripped bond schemes.

The First-tier Tribunal ruled in the Revenue’s favour in Malcolm Healey TC2591 and Philip Savva TC2625, two cases involving similar products marketed by banks as investments.

Incomplete submissions are resulting in “unnecessary delays” in the Liechtenstein disclosure facility (LDF) system, HMRC have warned.

The department's LDF helpdesk has sent a letter to specialist advisers stating that tax officials will adopt a “more robust stance… when determining whether a disclosure certificate can be issued in an LDF case”.

Special Metals and Engineering Ltd (TC2362)

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