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HM Revenue & Customs (HMRC) enquiry windowslimitation periods
  • Herbert Smith Freehills LLP
  • United Kingdom
  • April 29 2010

From 1 April 2010, changes introduced by Schedule 39 Finance Act 2008 will take effect and reduce the period within which HMRC can bring an assessment to four years from the end of the accounting period in the case of innocent errors, six years for careless errors and 20 years for deliberate mistakes


UK SDRT charge on an issue of ADRs in respect of shares in a UK company breaches EU law
  • Herbert Smith Freehills LLP
  • United Kingdom
  • April 3 2012

The recent First tier Tribunal decision in HSBC Holdings and Bank of New York Mellon Corporation v The Commissioners for HMRC contains good news for companies located in Europe seeking to raise capital


"Extreme shopping": HMRC legislation to counter treaty shopping: thoroughly draconian
  • Herbert Smith Freehills LLP
  • United Kingdom
  • August 5 2011

On 1 August, just before the summer break, HM Revenue & Customs (HMRC) published a "Technical Note" and draft legislation (together, the "Note") entitled "Tax Treaties Anti-avoidance"


Denial of input VAT deduction for failure to identify a connection with VAT fraud Court of Appeal in Mobilx rejects HMRC test of knowledge but requires traders to consider the circumstances of each trade or transaction
  • Herbert Smith Freehills LLP
  • United Kingdom
  • October 18 2010

It was reported on 7 September 2010 that HMRC have identified the first cases of attempted VAT fraud in the wholesale gas and power markets


Budget 2015 - no great surprises but a few disappointing features
  • Herbert Smith Freehills LLP
  • United Kingdom
  • March 19 2015

Yesterday, the Chancellor of the Exchequer handed down his final Budget before the UK's general election in May. It was a Budget with no great


Budget 2014 - a budget for makers, doers and savers
  • Herbert Smith Freehills LLP
  • United Kingdom
  • March 20 2014

The Chancellor of the Exchequer yesterday handed down his 2014 Budget. He described it as a Budget for "makers, doers and savers". Certainly, there


UK Supreme Court refuses to extend privilege to accountants
  • Herbert Smith Freehills LLP
  • United Kingdom
  • January 23 2013

The Supreme Court confirmed today that legal advice privilege ("LAP") cannot be claimed in respect of confidential communications between accountants


Government procurement rules: tax compliance is a factor to be considered
  • Herbert Smith Freehills LLP
  • United Kingdom
  • February 19 2013

The proposed rules require: Suppliers seeking to secure a government contract to self-certify during the selection stage of the procurement process


Government procurement rules: tax compliance is a factor to be considered
  • Herbert Smith Freehills LLP
  • United Kingdom
  • February 14 2013

With effect from 1 April 2013, Her Majesty's Government will use the procurement process to secure compliance with UK and foreign tax obligations


Autumn Statement 2014 - Autumn leaves its stamp on tax avoidance
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 4 2014

The Chancellor of the Exchequer yesterday handed down his 2014 Autumn Statement. He made a number of announcements which will impact the UK tax