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12 March 2018

Patrick’s Analysis of Recent JR’s of HMRC Search Warrants

Several recent judicial review cases have resulted in search warrants obtained by HMRC being quashed and the searches executed pursuant to the warrants being declared unlawful….
30 November 2017

A Material Misrepresentation of Facts by HMRC

Patrick Cannon recently acted jointly for the taxpayers in successfully challenging by way of a judicial review two search warrants obtained by HMRC from Blackfriars Crown…
27 May 2016

Guide to the 3 per cent Additional Charge

Read my updated guide based on the Finance (No 2) Bill 2016 provisions Access the guide here
20 October 2015

Invoking the Human Rights Act

The Human Rights Act is becoming increasingly relevant to tax investigations as HMRC adopt a more aggressive approach. Read my summary of the current position via…
20 January 2015

Project Blue

Gordon Keenay, head of Stamp Taxes at FTI Consulting has examined the judgment of the UT in Project Blue and has generously supplied his erudite analysis…
29 March 2013

Sub-sale Relief – Backwards and Forwards

The Finance Bill 2013 provisions withdraw the exemption from SDLT for certain sub-sales back to 21st March 2012 and also contain what will become the new…
17 September 2012

HMRC Win Vardy Properties Company Sub-Sale Appeal

Although HMRC have won in the First-Tier Tribunal in the Vardy Properties case there is nevertheless some encouragement for other versions of sub-sale schemes. HMRC have won…
25 November 2011

Property Exchanges, SDLT and VAT

How is VAT to be taken into account? Before FA 2011 where an exchange of land involved a freehold or a lease each party paid SDLT…
16 February 2011

E Guide to HMRC’s enquiry powers

The new e guide to HMRC’s enquiry powers is available and reflects the law as it will be from 1st April 2011. Please use the drop-down…