HMRC powers and enquiries

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Practice notes
Capital gains tax issues on deathSTOP PRESS: The Office of Tax Simplification published its first report on the review of capital gains tax (CGT) on...
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19th May
Practice notes
What is an offshore trust?A trust is formed either by lifetime gift or on death when a person (the settlor) transfers assets to another person or...
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Produced in partnership with Mourant Ozannes and Carey Olsen 19th May
Practice notes
Taxation of age 18–25 trusts—IHTThe special category of age 18–25 trusts was introduced by Finance Act 2006 (FA 2006) to offer some compensation for...
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Produced in partnership with Paul Davies of Clarke Willmott 19th May
Practice notes
Private Client—Luxembourg—Q&A guideTaxation regimeWhat factors determine tax liability in your jurisdiction (eg domicile, residence or...
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Produced in partnership with Eric Fort of Arendt & Medernach 19th May
Practice notes
CGT—reliefsFORTHCOMING CHANGE: On 14 July 2020, the Office of Tax Simplification (OTS) published its online survey and a call for evidence to seek...
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19th May
Q&As
When can a mistake in an executed deed be rectified by a manuscript amendment rather than by a deed of rectification?This Q&A explains when it is...
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Produced in partnership with Emma Holland of Stewarts Law 19th May
Practice notes
Trustees—statutory powers of trusteesSource and availabilitySourcesTrustees have certain powers conferred on them by statute, in particular by the...
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19th May
Practice notes
Creation of trusts—blind trustsWhat is a blind trust?A blind trust is a trust that is aimed at preventing conflicts of interest arising. Usually, the...
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Produced in partnership with Michael O’Sullivan of 5 Stone Buildings 19th May
Practice notes
Capacity to litigateOn the face of it, there would appear to be no specific impediment, if there is no reason to suppose that a person is without...
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19th May
Practice notes
Termination of trusts—methods of terminationDuration of a trustThe duration of an express trust is subject to the restrictions imposed by the rules...
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19th May
Practice notes
Costs and expenses in the Court of ProtectionThere are court fees and disbursements which will be payable by all applicants on making a new...
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19th May
Practice notes
Trust disputes—court jurisdiction and procedureTrust litigation has been classified as being of three types:•a dispute as to the trusts on which...
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19th May
Practice notes
Trustees—self-dealing, unauthorised profits and conflicts of interestThe self-dealing ruleThe self-dealing rule is connected to, but distinct from,...
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19th May
Practice notes
Statutory Wills—Court of Protection applicationsWhat is a statutory Will?Where a person is incapable of making a valid Will for themselves, the Court...
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19th May
Practice notes
Cayman Islands STAR trusts—common usesThis Practice Note provides guidance on Cayman Islands STAR trusts. For general information about the Cayman...
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Produced in partnership with Mourant Ozannes and Carey Olsen 19th May
Practice notes
Beneficial ownership registers—private clients and trustsCORONAVIRUS (COVID-19): Certain aspects of the PSC regime are affected by temporary measures...
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19th May

Most recent HMRC powers and enquiries content

Practice notes
HMRC compliance checks, enquiries and discoveryThere are various options open to HMRC when it suspects that tax has not been paid, or has been...
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3rd Aug
Practice notes
HMRC information powersHMRC's powers to check a person's tax position are in Schedule 36 to the Finance Act 2008.The powers enable HMRC to:•obtain...
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2nd Aug
Q&As
What is the meaning of ‘possession or control’ in the context of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009, SI 2009/273,...
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1st Aug
Q&As
Where a discovery amendment has been made to the tax return of a dissolved, trading limited liability partnership under section 30B of the Taxes...
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Produced in partnership with Denis Edwards of Normanton Chambers 1st Aug
Q&As
Following the Supreme Court’s decision in Derry, does a notice of enquiry into a tax return have to specify why the enquiry has been opened?HMRC can...
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31st Jul
Practice notes
HMRC inspection powersHMRC's powers to check a person's tax position are in Schedule 36 to the Finance Act 2008.The powers enable HMRC to:•obtain...
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31st Jul
Practice notes
HMRC criminal investigations and dawn raidsHMRC can investigate suspected tax-related criminal offences in England and Wales using the powers, and...
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31st Jul
Practice notes
Discovery assessments—sufficient disclosure of informationSometimes HMRC will come to the view that a taxpayer has paid, or been assessed for, too...
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Produced in partnership with Cathya Djanogly 31st Jul
Practice notes
HMRC data-gathering powersHMRC's information powers in Schedule 36 to the Finance Act 2008 (FA 2008) (see Practice Note: HMRC information powers) are...
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30th Jul
Practice notes
Direct recovery of tax debts (DRD)Direct recovery of tax debts (DRD) refers to HMRC's ability to instruct banks and building societies (ie...
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30th Jul
Practice notes
Civil tax fraud investigations—Code of Practice 9Civil investigation of tax fraudHMRC’s published policy in respect of tax fraud states that HMRC will...
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Produced in partnership with Corker Binning 30th Jul

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