HMRC powers and enquiries

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Practice notes
Direct tax treatment of damages and compensation paymentsWhere a dispute is brought to an end by a payment of damages or compensation, whether under a...
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19th May
Practice notes
Share sale or asset sale—tax considerationsThe sale of a company's business can be structured as either:•a sale of assets owned by the company (an...
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19th May
Practice notes
SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes
VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 19th May
Practice notes
How employment income is taxed—non-cash earnings or benefitsIn addition to cash earnings, such as wages or salaries, many reward packages include...
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19th May
Practice notes
UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQsWhat are the CDOT agreements?The UK entered into agreements with its three Crown...
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Produced in partnership with Ali Kazimi of Hansuke 19th May
Practice notes
Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
Practice notes
Corporation tax—connected personsThis Practice Note looks at the meaning of connected persons within sections 1122 and 1123 of the Corporation Tax Act...
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19th May
Practice notes
Property holding structures—direct tax treatment of a Jersey property unit trust (JPUT)STOP PRESS relating to property rich collective investment...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Practice notes
Section 198 and 199 elections on transactions involving real estateThis Practice Note describes the law and practice relating to elections under...
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Produced in partnership with Martin Wilson 19th May
Practice notes
Taxation of UK LLPsA UK limited liability partnership (LLP) is a body corporate for company law purposes, but is generally taxed as though it were a...
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19th May
Practice notes
The Budget and Finance Bill processThe Budget is a Parliamentary event at which the Chancellor of the Exchequer makes important announcements relating...
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19th May
Practice notes
Capital reduction demergersThe reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are...
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Produced in partnership with Zoe Feller of Bird & Bird 19th May
Practice notes
Why have a tax covenant?It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a...
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19th May

Most recent HMRC powers and enquiries content

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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19th 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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12th 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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12th Jul
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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7th Jul
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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6th Jun
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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6th Jun
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 6th Jun
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 5th Jun
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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5th Jun
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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5th Jun
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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5th Jun

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