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Results: 1-10 of 63

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


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


HMRC v Philips Electronics UK Limited
  • Herbert Smith Freehills LLP
  • United Kingdom, European Union
  • September 7 2012

On 6 September 2012 the CJEU delivered a clear ruling in favour of Philips, confirming that the UK provisions which prevent losses of UK branches of non-UK resident companies from being surrendered for group relief (section 107 CTA 2010 condition C, formerly section 403D(1)(c) ICTA 1988) constitute an unjustified restriction of the freedom of establishment under EU law


"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"


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


Supreme Court rules in judicial review on scope of duty of confidentiality owed by public bodies
  • Herbert Smith Freehills LLP
  • United Kingdom
  • November 11 2016

The Supreme Court has granted judicial review of a decision by Her Majesty's Revenue and Customs ("HMRC") to reveal confidential taxpayer information


ECJ rules that the stamp duty reserve tax charge on entry into a clearance system is illegal under EU law; may have wider implications
  • Herbert Smith Freehills LLP
  • European Union, United Kingdom
  • October 5 2009

In a case last week, HSBC Holdings plc and Vidacos Nominees Ltd v HMRC (C-56907), the European Court of Justice (“ECJ”) held that the 1.5 UK stamp duty reserve tax ("SDRT") charge on the issue of shares into EU clearance systems is illegal


HMRC's new procedure for investigating suspected serious tax fraud
  • Herbert Smith Freehills LLP
  • United Kingdom
  • February 8 2012

HMRC's "tougher procedures" for "civil" fraud investigations came into force on 31 January 2012


The Court of Appeal considers proportionality in judicial review
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 23 2016

The Court of Appeal has held in J P Whitter (Waterwell Engineers) Limited v The Commissioners for Her Majesty's Revenue and Customs 2016 EWCA


Tax effect of BREXIT - May 2016
  • Herbert Smith Freehills LLP
  • European Union, United Kingdom
  • May 26 2016

This article has been prompted by the current debate and forthcoming referendum in the UK on the UK's membership of the European Union ("EU") and