HMRC powers and enquiries

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Practice notes
FORTHCOMING CHANGE: HMRC is consulting (13 July to 10 August 2020) on draft regulations to provide a deduction from a UK entity’s equity and...
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Produced in partnership with Charlotte Sallabank of Katten Muchin Rosenman UK LLP 12th Jan
Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
It is standard market practice for loan agreements (also known as facility agreements), whether bilateral or syndicated, to:•prohibit a borrower from...
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Produced in partnership with Eloise Walker of Pinsent Masons 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent HMRC powers and enquiries content

Practice notes
There are various options open to HMRC when it suspects that tax has not been paid, or has been underpaid. These include:•issuing a determination—this...
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19th Apr
Practice notes
HMRC's powers to check a person's tax position are in Schedule 36 to the Finance Act 2008.The powers enable HMRC to:•obtain documents and information,...
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9th Apr
Practice notes
Sometimes HMRC will come to the view that a taxpayer has paid, or been assessed for, too little tax, but will come to this view at a time when it is...
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Produced in partnership with Cathya Djanogly 9th Apr
Practice notes
HMRC can investigate suspected tax-related criminal offences in England and Wales using the powers, and subject to the safeguards, in the Police and...
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9th Apr
Practice notes
HMRC's information powers in Schedule 36 to the Finance Act 2008 (FA 2008) (see Practice Note: HMRC information powers) are supplemented by...
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9th Apr
Practice notes
Direct recovery of tax debts (DRD) refers to HMRC's ability to instruct banks and building societies (ie deposit-takers) to deduct amounts to settle...
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9th Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 introduces a new ‘financial institution notice’ (FIN) that can require financial institutions to provide...
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11th Mar
Practice notes
Civil investigation of tax fraudHMRC’s published policy in respect of tax fraud states that HMRC will seek to use a civil rather than criminal...
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Produced in partnership with Corker Binning 26th Feb
Q&As
Rule 16(1) of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (TP(FTT)(TC)R 2009), SI 2009/273, provides as follows (our...
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29th Nov
Q&As
HMRC can open an enquiry into a tax return by giving notice of an enquiry to the taxpayer (or their agent) within certain time limits (referred to as...
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29th Nov

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