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361 results found

Article

RPC | United Kingdom | 10 Aug 2016

Taxpayer succeeds on penalties issue in Pendulum scheme

In a recent case the First-tier Tribunal (FTT) has found that a taxpayer was not fraudulent or negligent in the completion of his tax return when

Article

RPC | United Kingdom | 3 Jul 2014

HMRC fail to demonstrate negligence in tax planning case

In the case of R, A and M Gardiner v HMRC, the First-tier Tribunal (Tax Chamber) ('FTT') overturned penalties imposed by HMRC on the appellant

Article

RPC | United Kingdom | 6 Feb 2012

Mea culpa?

In an interesting development that should be welcomed by company directors in particular, the First-tier Tribunal held in O’Rorke v HMRC 2011 UKFTT 839 that a subjective test of neglect applies when determining whether a company’s failure to pay National Insurance Contributions (‘NICs’) can be attributed to neglect on the part of an officer (and thus render him or her personally liable to pay the unpaid NICs).

Article

RPC | European Union | 14 Nov 2011

Jackpot!

The ECJ have released their eagerly awaited judgment in the long running battle between Rank Group Plc and HMRC over the VAT treatment of gaming machines (see Commissioners for HMRC v Rank Group Plc C-25910 & C-26010).

Article

Squire Patton Boggs | United Kingdom | 7 Nov 2011

Discovery assessments

I am always on the look out for cases which involve discovery assessments because the opportunity for HMRC to raise assessments out of time is obviously very important indeed.

Article

RPC | United Kingdom | 19 Sep 2011

Managing tax disputes: HMRC’s approach to tax disputes and its litigation and settlement strategy more questions than answers?

Tax disputes arise for a range of different reasons: HMRC changes its policy or targets an avoidance scheme, a tax professional provides incorrect advice, or a taxpayer implements advice incorrectly.

Article

Squire Patton Boggs | United Kingdom | 5 Jul 2011

Taxpayer negligence

The recent case of Colin Moore v HMRC FTC822010 is rather alarming and represents a clear warning to anybody enclosing information with their tax return.

Article

Mills & Reeve LLP | United Kingdom | 24 Jun 2011

Solicitors in the firing line

While negligence claims against law firms are a fact of life, recessions cause a spike to occur both in terms of number and size of claim.

Article

Penningtons Manches LLP | United Kingdom | 18 Apr 2011

Stamp duty land tax group relief

Group relief is an exemption from stamp duty land tax (SDLT) which allows companies in the same group to move properties between themselves for commercial reasons without any SDLT implications.

Article

Nabarro LLP | United Kingdom | 11 Apr 2011

No more second bites for trustees: the end of the rule in Hastings-Bass

The rule in Hastings-Bass had been settled law for many years.

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