European Tax

If a tax treaty is engaged, it may be possible to ask HMRC to consider how that tax treaty will interact with the enquiry – that is what...

HMRC enquiries can be a frustrating process. There is no time limit for HMRC to complete an enquiry and enquires can continue for many...

Imagine a scenario where two companies are in a VAT group and one supplies investment management services to the other. Consideration for...

HMRC cannot demand disclosure of documents that are subject to legal professional privilege. However, it is not uncommon for HMRC to ask...

A notice of enquiry will almost always be accompanied by a request for information. In the previous blog of this series on tax disputes...

Robert Frost wrote of endings and beginnings that “there are no such things./ There are only middles”. This can feel particularly true of...

Given the challenging fiscal environment (evidenced yet again by a summer of deficit estimates and Budget speculation) and the...

Where are your pension payments taxed if you retire abroad? The UK’s First-tier Tribunal (FTT) had to grapple with this question in...

Not as far as HMRC would appear to want it to. The First-tier Tribunal’s procedural decision in Motorplus is another example of somewhat...

In October 2024, the UK Government announced as part of the budget that from 6 April 2027, “inherited pensions [will be brought] into...

The spectre of the section 899 “revenge” or “foreign investor” tax was still looming over us when we recorded a podcast with Arvind...

As we previously reported, on 28 April 2025 the UK government announced a technical consultation on draft legislation (the Draft...

How foolish I was for thinking that occasions such as an Autumn Budget or Spring Statement would no longer be followed by a “tax...

The UK’s Spring Statement delivered on 26 March 2025 did not include further tax increases and the Chancellor stuck to her commitment to...

The Court of Appeal published their decision in Gunfleet Sands on 17 March 2025, upholding the taxpayers’ appeal on the availability of...

What do tax lawyers talk about at lunch? In my case, it’s been the UK Supreme Court's majority decision (4:1) in Royal Bank of Canada. My...