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Results: 1-10 of 63

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


"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"


New UK criminal offences of failure to prevent facilitation of tax evasion
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 5 2016

In our October 2016 briefing, we reported on the publication of the Criminal Finances Bill 201617. The Bill introduces a range of new measures to


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
  • European Union, United Kingdom
  • April 26 2012

Advocate General’s opinion: UK loss relief rules for branches breach EU law


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


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


Retrospective tax legislation: compatible with the European Convention on Human Rights ("ECHR")
  • Herbert Smith Freehills LLP
  • United Kingdom
  • July 31 2015

Retrospective legislation, seeking to close a tax loophole relating to Stamp Duty Land Tax ("SDLT"), did not engage rights under the ECHR to the


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


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