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Staleness argument loses its bite

“Staleness” is an argument used in recent years by taxpayers – with some degree of success – to persuade the Tribunal that assessments raised by HMRC are invalid.  The point of law concerns the discovery provisions within Section 29 Taxes Management Act. The legislation allows a Revenue Officer to make an assessment if broadly he…

HMRC win tribunal case on “Aikido”

HMRC were successful in a First Tier Tribunal case in January in a challenge to the “Aikido” tax planning strategy. Although the case was not a test case as such, if the taxpayers (Ms Clipperton and Mr Lloyd) have not appealed the decision within the time limit, it becomes a “final ruling” which allows HMRC…

Do you know your Bitcoin tax bill?

At the time of writing, Bitcoin is trading at $53,000 (over £37,000).

A few days ago, its value reached an all-time high of $58,000. Other cryptotokens have also soared in value.

HMRC domicile enquiries

In this article we take a look at the growing number of domicile enquiries by HMRC, which looks set to increase further following their recent success in the Henkes case,