The perils of signing the Contractual Disclosure Facility or (CDF) disclosure form which states: “Under the terms of the CDF, I admit that my deliberate conduct…
“Mediation as a means of resolving commercial disputes involving tax has been around for ages but has only come to the fore in disputes with HMRC…
In a major U-turn, HMRC have now offered to supply taxpayers with “further advice about how to proceed” if they are unclear about whether section 75A…
Since 30 September, 2017 companies and partnerships that do not have reasonable procedures in place to prevent employees, agents or subsidiaries from facilitating tax evasion may…
Patrick Cannon spoke to a packed Chambers’ client seminar in the Old Hall in Lincoln’s Inn on the 7th March 2019 on current points of contention…
Read my guide to the 3% additional SDLT charge now updated for the changes made by FA 2019 here.
HMRC has quietly changed its approach to stamp duty land tax on mixed-use property purchases to make it much more difficult to claim the (lower) Table…
Read my guide to the 3% additional SDLT charge now updated for the changes made by FA 2018 here.
This decision in my own penalty appeal emphasises the importance of HMRC keeping an open mind and not pursuing to a full appeal hearing a “myopic”…