Spurs 2 HMRC 0: Tax on termination payments

Following the First-tier Tribunal decision in HMRC v Tottenham Hotspur Ltd in 2016 concerning termination payments paid to transferring footballers ([2016] UKFTT 389 (TC)), the Upper Tribunal [2017]... Read more

HMRC Information Powers by Mark McLaughlin

Most practitioners will be aware of HMRC’s statutory powers to obtain information and documents from the taxpayer which are reasonably required by HMRC for the purpose of checking the taxpayer’s tax... Read more

Paper tax returns and penalties – Take care when sending documents to HMRC by post.

An article by Mark McLaughlin Read more

Close company participators: The 25% charge

An article by Mark McLaughlin Read more

HMRC enquiries - Undisclosed company profits taxed as loans to participators

It is not uncommon for HMRC enquiries into the business accounts of an individual or company to result in additions to turnover and profits. For example, unexplained lodgements into a private bank... Read more

Small business tax – HMRC’s consultation on simplifying business tax

The Government seems intent on simplifying tax for small businesses. The Office of Tax Simplification (OTS) published three documents in February 2012. One document dealt with HMRC administration,... Read more

Transactions in securities – The revised rules two years on.

The anti-avoidance provisions regarding Transactions in Securities (TiS) have been around in one form or another since the 1960s. Such is the significance of the provisions that even many non-tax... Read more

HMRC Enquiries

Most tax agents involved with enquiry work will be familiar with the HMRC practice of 'spreading'. This generally occurs when there is an agreed addition to the taxpayer's income for the year of... Read more

Penalties and costs – The taxpayer fights back

Taxpayers have recently been successful in a number of appeals before the tax tribunal on the grounds of ‘reasonable excuse’, mainly in respect of late filing penalties. One such case is highlighted... Read more

HMRC Information notices

Taxpayers can be required to provide HM Revenue and Customs (HMRC) with certain information and/or documents, if HMRC issues a written notice to that effect (FA 2008, Sch 36, para 1; previously TMA... Read more

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