Recovering Legal Fees if Successful on Appeal
Ordinarily, neither HMRC nor the taxpayer can recover costs if they are successful. This was introduced in 2009 so that taxpayers could appeal without [...]
HMRC ‘Best Judgement’ Assessments
This has always angered CTM clients because it seems that HMRC can simply make up a figure, which is generally inflated, and little can be [...]
Late Appeal to Tax Tribunal
Appealing late to the First-Tier Tax Tribunal needs to be very carefully worded and must reflect the case law that is commonly used in [...]
Personal Penalties
HMRC have the power to raise penalties for tax returns that are thought to be deliberate. They do not have to prove that the [...]
HMRC Raising Tax Assessments Out of Time
Many business are receiving VAT, or Corporation Tax, assessments for incorrect tax returns submitted years earlier. HMRC have 2 years to raise an assessment [...]
HMRC Pleadings in Fraud Cases
The Court of Appeal in Northern Ireland overturned a decision of the First-Tier Tax Tribunal and the High Court regarding how HMRC must plead [...]
Drilling rigs can use red diesel
In another CTM case, HMRC had changed its interpretation of the law when it came to the use of red diesel in vehicles that [...]
Taxpayers right to allocate VAT payments to current periods even when in arrears?
The law had always seemed to be on the side of HMRC when it came to allocating VAT payments. If the company was in [...]
HMRC Debt Recovery
Probably the No.1 question we receive relates to HMRC’s tax debt collection mechanism. Whether it’s VAT, Corporation Tax or personal tax, HMRC will pursue [...]