HMRC suffer rare defeat on Discovery

Ranga Nelson v The Commissioners for HMRC concerned discovery assessments and penalties for the years 2007/08 to 2012/13. HMRC had issued assessments based on the Appellant’s ‘deliberate’ behaviour in relation to the reporting of trading profit and the apparent shortfall of income compared with expenditure.

Loan charge, review and options

I have previously acknowledged the work of LCAG in securing the review of the loan charge, now due to be published no later than 30th March 2019. It was a great effort….

Complaining about HMRC – Headway or Headache?

According to the HMRC annual report and accounts of 2017-18, 69% of individuals, small businesses and agents rated their overall experience with HMRC as positive. This begs the question as to why HMRC received 77,410 new complaints? Of these complaints, HMRC claim that 99% are resolved internally.

Lords Economic Affairs Committee report into The Powers of HMRC: Treating Taxpayers Fairly

Following an extensive evidence gathering exercise, their Lordships have published the latest in a series of reports into the current Finance Bill and its predecessors. This, the fourth report of the session, is particularly damning of Government policy and HMRC’s delivery of it, in dealing with the treatment of taxpayers accused of tax avoidance. Whilst […]

In a moment of Discovery

Isaac Newton was sitting in his garden when an apple fell on his head and in a stroke of brilliance, he formed his theory of gravity. Discoveries can be sudden and unexpected, or they can arise from a process of deliberate and careful planning induced by curiosity and/or necessity. Assessment letters under Section 29 TMA […]

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