We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 50

Gaines-Cooper decision UK tax residence for individuals
  • Herbert Smith Freehills LLP
  • United Kingdom
  • April 29 2010

The recent decision of the Court of Appeal in Gaines-Cooper (R (on the application of (1) Robert John Davies (2) Michael John James) v Revenue & Customs Commissioner: R (on the application of Robert Gaines- Cooper) v Revenue & Customs Commissioners 2010 EWCA Civ 83) has attracted a great deal of publicity


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


"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


UK Uncut Legal Action Ltd v HMRC (Goldman Sachs International and Goldman Sachs Services Ltd, interested parties)
  • Herbert Smith Freehills LLP
  • United Kingdom
  • May 28 2013

This case relates to an administrative law challenge, by a member of the public, to a proposed compromise between HMRC and taxpayers (Goldman Sachs


Emergency Budget
  • Herbert Smith Freehills LLP
  • United Kingdom
  • July 6 2010

The Chancellor of the Exchequer handed down his Emergency Budget on 22 June 2010


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


Appeals against conclusions set out in a closure notice HMRC v Tower MCashback (decision of the Court of Appeal)
  • Herbert Smith Freehills LLP
  • United Kingdom
  • February 5 2010

On an appeal by a taxpayer against the conclusions set out in a closure notice, HMRC may only raise and rely on grounds in support of its conclusions which relate to the subject matter of the enquiry (as determined by the First-tier Tribunal


Emergency Budget June 2010
  • Herbert Smith Freehills LLP
  • United Kingdom
  • June 22 2010

Today's Budget delivered by the Chancellor of the Exchequer is peppered with good and bad news for individual and business taxpayers alike


Budget measures included in the Finance Act 2010
  • Herbert Smith Freehills LLP
  • United Kingdom
  • April 29 2010

The Chancellor of the Exchequer handed down his Budget on 24 March 2010 and the Finance Act received Royal Assent on 8 April 2010