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Results: 1-10 of 60

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


Policy guidance given by HMRC may give rise to a general legitimate expectation
  • Herbert Smith Freehills LLP
  • United Kingdom
  • July 18 2016

In R (Biffa Waste Services Limited) v the Commissioners for HMRC 2016 EWHC 1444 (Admin), the claimant company ("Biffa") challenged HMRC's


Resolving disputes with HMRC
  • Herbert Smith Freehills LLP
  • United Kingdom
  • July 20 2015

This is the eighth in our series of ADR practical guides, designed to provide clients with essential practical guidance on various processes falling


Autumn Statement 2012
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 5 2012

Today, the Chancellor of the Exchequer handed down his Autumn Statement


Summer budget 2015
  • Herbert Smith Freehills LLP
  • United Kingdom
  • July 9 2015

The Chancellor of the Exchequer yesterday handed down his second Budget of 2015. It was his first Budget without the Liberal Democrats, and


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


"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"


Penalty for failure to notify tax avoidance scheme - reliance on counsel's opinion - nil penalty
  • Herbert Smith Freehills LLP
  • United Kingdom
  • March 18 2009

The Special Commissioner in the case of HMRC v Mercury Tax Group Ltd considered (obiter) the penalty to be applied to a taxpayer for a failure to notify a tax avoidance scheme under Part 7 of the Finance Act 2004


HMRC clampdown on tax avoidance: banks in the firing line
  • Herbert Smith Freehills LLP
  • United Kingdom
  • March 1 2012

Following a disclosure by a bank (now confirmed as Barclays) HMRC, on 27 February 2012, published proposed new legislation aimed at closing loopholes in the rules in the loan relationship legislation dealing with the buy-back of impaired debt by connected companies (also known as the "deemed release" rules


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