Whatever emerges after next year’s General Election, there will be disputes around UK tax domicile claims for years to come. However, the approach taken by the Courts towards witness evidence in tax disputes has already changed, and so therefore must the advice given to clients.

HMRC’s review of COP9 is continuing and there may be further developments in Q4 of 2023. The COP9 process remains an opportunity to put things right and, if well handled, is often the best framework for taxpayers to resolve deliberate tax understatements. However, where the opportunity to make full disclosure is not taken, or a COP9 is mishandled, it is clear that the risks of criminal prosecution are increasing.

HMRC doesn’t need to look for signs of letting income- it already has the data.

HMRC is launching a new campaign in September 2022 to tackle non-compliance linked to offshore corporates owning UK properties.

Tough disputes with HMRC can be necessary, but understanding all the options is key to resolution. How do you find the right path?

The Supreme Court’s judgement in Tooth was one of the more significant tax decisions of 2021, and will shape future interpretation of HMRC’s assessing powers

HMRC has committed to producing new guidance by summer 2021 on its approach to penalties.