Taxing Matters

HMRC's approach to supply chain fraud, with Joshua Carey of Devereux Chambers

Thu, 05 Feb 2026 12:01:28 GMT

In this episode of RPC’s Taxing Matters podcast, Michelle Sloane, Partner in our Tax, Investigations and Financial Crime team, is joined by Joshua Carey of Devereux Chambers to explore HMRC’s increasingly robust approach to supply chain fraud, and what this means in practice for businesses.

Drawing on their extensive experience in complex tax and public law disputes, Michelle and Joshua discuss:

how supply chain fraud can arise and how businesses can find themselves implicated, sometimes unwittingly, in these chains
HMRC’s investigative toolkit and the legal framework it relies on, including the “knew or should have known” test
the growing use of penalty provisions that can affect both corporate entities and individuals
the potential civil, criminal and reputational consequences of being caught up in a fraudulent supply chain
what businesses can do to help protect themselves.

Thank you for listening to this episode. You can listen to and subscribe to Taxing Matters on Apple Podcasts and Spotify and stay up to date with developments in the tax world.

If you would like to discuss any of the matters raised in this episode, or find out more about our tax services, please contact Adam Craggs or Michelle Sloane.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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A very VATy Christmas with Philip Simpson KC from Old Square Tax Chambers

Tue, 16 Dec 2025 09:00:00 GMT

In this festive edition of Taxing Matters, RPC’s Senior Associate and Taxing Matters host, Alexis Armitage, is joined by Philip Simpson KC of Old Square Tax Chambers, well known VAT expert and part-time stand-up comedian. Together, they embark on an insightful sleigh ride through the VAT implications of classic Christmas fare, decorations, and traditions, demystifying which seasonal treats and trimmings may attract HMRC’s attention.

From turkey and pigs in blankets, to mince pies and cheese boards, this special episode looks at the tax treatment of festive favourites.

Thank you for listening to this episode. You can listen to and subscribe to Taxing Matters on Apple Podcasts and Spotify and stay up to date with developments in the tax world. If you would like to discuss any of the matters raised in this episode, or find out more about our tax services, please contact Adam Craggs or Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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Unpacking the complexities of tax deed claims with Jivaan Bennett of Temple Tax Chambers

Wed, 03 Dec 2025 09:00:00 GMT

In this episode of Taxing Matters, Alexis Armitage, Senior Associate in RPC’s Tax Disputes team, is joined by Jivaan Bennett of Temple Tax Chambers. Jivaan brings nearly 15 years of international experience in tax, commercial transactions, and disputes, having worked across the Caribbean, London, and New York.

Together, Alexis and Jivaan discuss the complexities of tax deed claims in the context of corporate transactions, offering practical insights for both lawyers and businesses. Key topics covered in this episode, include:

· the definition and purpose of tax deeds, and their distinction from tax warranties

· strategic considerations for making and defending tax deed claims

· common drafting issues and the importance of clear contractual language

· the interaction between tax deed claims and tax authority inquiries

· recent trends, including increased use of arbitration and insurance.

Thank you for listening to this episode. You can listen to and subscribe to Taxing Matters on Apple Podcasts and Spotify and stay up to date with developments in the tax world.

If you would like to discuss any of the matters raised in this episode, or find out more about our tax services, please contact Adam Craggs or Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

Hosted on Acast. See acast.com/privacy for more information.

The Court of Appeal's decision in A Taxpayer v HMRC with Rebecca Sheldon, Old Square Tax Chambers

Wed, 19 Nov 2025 09:00:00 GMT

In this episode, Alexis Armitage, Taxing Matters host and Senior Associate at RPC, speaks with Rebecca Sheldon of Old Square Tax Chambers, about the Court of Appeal’s recent decision in A Taxpayer v HMRC, in which Rebecca was instructed on behalf of the taxpayer.

The discussion focuses on how "exceptional circumstances" under the Statutory Residence Test (SRT) should be interpreted, particularly where personal and moral obligations are involved.

Join Alexis and Rebecca as they discuss:

the background of the case and why HMRC challenged the taxpayer’s UK residency status
the SRT and the meaning of "exceptional circumstances"
why the taxpayer's claim under the SRT is of particular interest
the journey of the case through the FTT, the UT and finally the Court of Appeal
how the case is relevant for other taxpayers seeking to rely on "exceptional circumstances" in the context of the SRT
the key lessons from the decision for taxpayers and advisors on evidence and planning residency days.

Thank you for listening to this episode. You can listen to and subscribe to Taxing Matters on Apple Podcasts and Spotify and stay up to date with developments in the tax world.

If you would like to discuss any of the matters raised in this episode, or find out more about our tax services, please contact Adam Craggs or Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

Hosted on Acast. See acast.com/privacy for more information.

Top tips for tax litigation with Jonathan Davey KC from Wilberforce Chambers

Wed, 22 Oct 2025 08:15:00 GMT

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by Jonathan Davey KC, of Wilberforce Chambers, one of the UK’s leading barristers in commercial chancery work with a particular focus on tax, trusts and property.

Jonathan shares his practical insights and top tips for navigating the complexities of tax litigation, drawing on decades of experience at the Bar; from keeping cases simple and crafting compelling narratives, to mastering the detail of documentary evidence and knowing when to settle.

Whether you are a tax advisor, litigator, or in-house counsel, this episode offers useful tips for anyone involved in tax disputes and litigation against HMRC.

If you would like to discuss any of the matters raised in this episode, or find out more about our tax litigation offering, please contact Adam Craggs or Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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Wealth management for creatives – navigating financial planning in the entertainment industry

Wed, 24 Sep 2025 07:00:00 GMT

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by Simon Reed, Director and wealth manager at RBC Brewin Dolphin, and head of the Entertainment, Media & Sports client segment in London. Together, they delve into the unique financial challenges faced by clients in the creative industries, including actors, musicians, and digital creators.

Join Alexis and Simon in this month's episode as they discuss:

the complexities of managing unpredictable income streams
the importance of early wealth planning for creatives
working collaboratively with tax lawyers and accountants on cross-border and residency issues
protecting and monetising intellectual property (IP)
emerging trends in long-term financial planning, including pensions, succession, and philanthropy
the rise of new client types in the digital creator economy and their distinct advisory needs.

Whether you advise creatives or are part of the entertainment sector yourself, this episode offers practical insights on how to navigate wealth management and maximise after-tax returns in a rapidly evolving industry.

Our Tax, Investigations and Financial Crime team advise individuals and businesses on a range of complex tax matters. The team is ranked Band 1 in the Chambers High Net Worth Guide for Tax: Private Client. If you would like to discuss any of the matters raised in this episode, or find out more about our work for high net worth clients, please contact Adam Craggs or Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

Notice from RBC Brewin Dolphin:

RBC does not offer tax advice and this does not constitute tax or legal advice. Tax treatment depends on the individual circumstances of each client and may be subject to change in the future.
The value of investments, and any income from them, can fall and you may get back less than you invested
Information is provided only as an example and is not a recommendation to pursue a particular strategy.

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The countdown to failure to prevent fraud is on (Part 3): Looking ahead: further developments for corporate criminal liability

Thu, 31 Jul 2025 07:00:00 GMT

From 1 September 2025, the new failure to prevent fraud offence will come into effect under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Statutory guidance from the Home Office sets out the framework that large organisations should implement by September 2025, to ensure they have in place reasonable fraud prevention procedures.

In this three-part special of RPC's Taxing Matters podcast, RPC's Tom Jenkins, Of Counsel and Financial Crime specialist joins Alexis Armitage, RPC's Taxing Matters podcast host to discuss the new offence and its potential impact on businesses, and other developments relevant to the law of corporate criminal liability.

In the final episode of the series, Alexis Armitage and Tom Jenkins discuss the future of corporate criminal liability, focusing on new and upcoming legal developments.

In this episode, they discuss:

developments regarding “failure to prevent” offences, including bribery, facilitation of tax evasion, and the forthcoming fraud offence
the potential impact of the proposed Crime and Policing Bill, which could significantly broaden corporate liability further, including in relation to non-financial crime offences
key considerations for organisations in preparation for 1 September 2025, including compliance, training, and risk assessment.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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The countdown to failure to prevent fraud is on (Part 2): What is failure to prevent fraud?

Thu, 24 Jul 2025 07:00:00 GMT

In the second episode of our series, Alexis and Tom dive into the new failure to prevent fraud offence, which comes into force in September 2025 under the Economic Crime and Corporate Transparency Act, and discuss:

details of the new offence and who it will apply to
which fraud offences are in scope
an analysis of its effect on large organisations and smaller businesses
jurisdictional scope, including risks for overseas companies
the “reasonable procedures” defence and six key compliance principles
what businesses should be doing now in readiness

Stay tuned for the final episode in our series as we look at what might be coming next in this fast-moving area of the law.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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The countdown to failure to prevent fraud is on (Part 1): A recap on corporate criminal liability

Thu, 17 Jul 2025 07:00:00 GMT

Part 1: A recap on corporate criminal liability

In part 1, Alexis and Tom look at how the law around corporate criminal liability is changing and discuss:

the historic “identification doctrine” and its limitations for law enforcement bodies when seeking to prosecute companies
key criticisms of the old law and why reform was needed
the major changes introduced by the Economic Crime and Corporate Transparency Act, including the new legal test for attributing criminal liability to companies
what counts as a “senior manager” under that new test and which offences are in scope
steps organisations should consider in response to this important change in the law.

Coming soon

Stay tuned for our next episodes as we take a more in depth look at the new failure to prevent fraud offence, and consider the future of corporate criminal liability.

Part 2: What is failure to prevent fraud? | Thursday 24 July
Part 3: Looking ahead: further developments for corporate criminal liability | Thursday 31 July

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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When tax advice goes wrong: professional negligence in tax disputes

Wed, 25 Jun 2025 12:59:04 GMT

In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by colleagues Helen Kerr and Tom Wild from RPC's Professional Liability team to explore how professional negligence claims can arise during the lifecycle of a tax dispute.

Together, they consider where advisers, particularly lawyers and accountants, face exposure to negligence claims, as they discuss:

the typical lifecycle of a tax dispute
common scenarios where negligence may occur
how courts assess negligence
the role of insurers in professional negligence cases
practical tips for advisers, lawyers, and insurers to prevent negligence

Whether you are a tax adviser or insurer, this episode offers insights into how tax advice can go wrong, and how to safeguard against it.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs or Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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Mental Health Awareness Week: breaking down mental barriers in the mind with Jo Maughan

Tue, 13 May 2025 08:00:00 GMT

In this special Mental Health Awareness Week episode of Taxing Matters, host Alexis Armitage welcomes Jo Maughan, career coach and former tax director, to discuss how professionals can manage their critical inner voice and break down mental barriers in their mind.

With many years of experience working in tax at BP and PwC, Jo understands the high-achieving, perfectionist mindset that tax professionals often develop. In this episode, Alexis and Jo explore:

the unique challenges professionals face in tax and other high-pressure jobs
how the critical inner voice is amplified by competitive work environments
practical tools for quieting self-doubt, including the FOG method (Fact, Opinion, Guess)
the importance of getting out of your head and into your body through mindfulness and movement.

As discussed on the podcast, if you would like to sign-up for Jo’s mindful walks in London and Guildford this summer, you can do so here.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs or Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

Hosted on Acast. See acast.com/privacy for more information.

Tax risk for professionals and professional businesses with Thomas Slipanczewski

Tue, 29 Apr 2025 07:00:00 GMT

In this episode of Taxing Matters, Senior Associate and Taxing Matters host, Alexis Armitage is joined by Thomas Slipanczewski, who is an Associate Director at Deloitte in their tax controversy team, to discuss task risk for regulated professionals and professional businesses in regulated sectors.

Facing a tax dispute or investigation can have a significant impact on an individual or business, and for those in regulated sectors such as lawyers, accountants and finance professionals, the associated reputational risks are often heightened. In this episode, Alexis and Thomas discuss:

risks that regulated professionals and professional businesses should be aware of when they have a tax dispute or investigation;
HMRC's perception of this taxpayer group and its implications; and
'top tips' for professional taxpayers facing a dispute or investigation.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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Navigating the human side of tax disputes with Mark Bevington of ADE Tax

Wed, 26 Mar 2025 09:00:00 GMT

In our latest episode of RPC's Taxing Matters, podcast host and Senior Associate, Alexis Armitage, is joined by Mark Bevington managing principal and founder of ADE Tax.

With over 30 years' experience working in tax, Mark is a highly experienced strategic tax advisor, who has advised on numerous significant and complex transactions, disputes, negotiation support, policy and planning matters.

In this episode, Alexis and Mark explore the human side of tax disputes and discuss:

the human elements of tax disputes and their potential impacts
the difference between commercial disputes and tax disputes
how complexities caused by the human side of tax disputes can be navigated
the potential emotional impacts of tax disputes on individuals
how mediation and ADR can help humanise the process
advice and 'top tips' for tax professionals and taxpayers on handling the human side of disputes.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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IWD 2025 special with Ele Theochari

Thu, 06 Mar 2025 07:00:00 GMT

This month, RPC Senior Associate and Taxing Matters host, Alexis Armitage, is joined by Ele Theochari, Partner at Blick Rothenberg for a special episode to celebrate International Women's Day.

Ele is an R&D specialist who was promoted to Partner at just 29. Ele is passionate about helping companies to access R&D tax incentives and seeing the positive impact that R&D tax credits can have on a business. In this episode Alexis interviews Ele about:

how she started her career in tax
her journey to Partner and the challenges she's faced
advice that previous mentors have given her
role models she's looked up to throughout her career
the charitable work she does alongside her day-to-day role.
top tips for those starting their careers in tax.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

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Mike Ashley wins landmark data protection case against HMRC

Thu, 27 Feb 2025 08:45:00 GMT

At the end of January, Mike Ashley won his high-profile and landmark data protection case against HMRC, with the High Court concluding that HMRC wrongly withheld his personal information for over two years.

In this month's episode of Taxing Matters, our host and Senior Associate, Alexis Armitage is joined by Megan Grew, Associate at RPC and part of Mike Ashley's legal team, to discuss the legal aspects of the case that led to a landmark data protection victory against HMRC for Mike Ashley in the High Court.

In this episode, they discuss:

the background to the case and how it got to the High Court
Mike Ashley's arguments v HMRC's arguments
the court's judgment in the case, including in respect of costs
practical implications of the win, and what this could mean for other individuals dealing with HMRC
key takeaways from the judgment for HMRC and other government bodies.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice. This episode discusses publicly available information only and does not disclose or imply any privileged or confidential details. RPC will not be providing further comments or media interviews on this matter.

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Nature's wealth: unlocking the power of natural capital with Daisy Darrell

Wed, 29 Jan 2025 15:07:09 GMT

In the latest episode of Taxing Matters, our host, Alexis Armitage is joined by Daisy Darrell, a Senior Associate in Birkett's Agricultural and Estates team to discuss all things natural capital.

Natural capital is the planet's natural wealth and the idea that the world has a stock of natural assets which provide ecosystem services like clean air, fertile soil and pollination of crops.

Join Alexis and Daisy as they explore:

opportunities that natural capital can create for landowners
examples of recent environmental enhancement and restoration projects
the environmental benefits of such projects
tax considerations for farmers and landowners
potential impacts of ESG on natural capital markets

We hope you enjoy the episode. Please subscribe on Apple Podcasts or Spotify to keep up with future episodes.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice. Opinions expressed by the speakers are their own and do not necessarily represent the views or opinions of RPC.

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Deck the halls… with weird and wonderful taxes throughout history

Mon, 09 Dec 2024 17:00:22 GMT

In our special Christmas episode, Alexis Armitage, RPC's Taxing Matters podcast host and Senior Associate in our Tax Disputes and Investigations team, is joined by Andrew Hubbard, editor-in-chief of Tolley's Taxation Magazine. From candles to beards, join them as they discuss the most bizarre taxes that have existed throughout British history.

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ADR in tax disputes with HMRC's ADR lead, Fiona McRobert

Mon, 25 Nov 2024 16:08:50 GMT

In this month's episode of Taxing Matters, Alexis Armitage is joined by HMRC's Alternative Dispute Resolution (ADR) lead, Fiona McRobert, to discuss HMRC's approach to the ADR process, and how tax disputes may be resolved outside the Tax Tribunals and the court system.

During this episode they discuss:

how the ADR process differs from formal litigation or an internal HMRC review
the types of cases considered suitable for ADR (and those not suitable)
the role of the mediator
potential outcomes of the ADR process
timelines and practicalities involved in the ADR process
the pros and cons of ADR
ADR success rates
top tips.

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Crystal ball gazing with Jasprit Singh

Tue, 22 Oct 2024 08:30:27 GMT

In this episode, Alexis Armitage, RPC's Taxing Matters podcast host and Senior Associate in our Tax Disputes and Investigations team, is joined by colleague and fellow Senior Associate, Jasprit Singh. Join them as they gaze into their crystal ball and predict what could be on the horizon for taxpayers under the new Labour government.

This episode covers:

Labour's upcoming autumn budget
HMRC's next potential targets and what they may focus on in the coming months
the potential role of AI in HMRC's plans

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Taxation of agents' fees in the football industry

Mon, 16 Sep 2024 15:31:15 GMT

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes and Investigations team, is joined by colleague and Partner, Michelle Sloane, to discuss the latest issues surrounding the taxation of agents' fees in the football industry.

This episode covers:

the financial relationship between players, their clubs and their agents
HMRC's position on the tax split
what clubs can do to evidence that the split reflects the commercial reality of the arrangement
the high risk areas most likely to be investigated by HMRC.

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Spotlight 63: HMRC shines a light on property business arrangements involving hybrid partnerships

Mon, 15 Jul 2024 15:04:26 GMT

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Simon Howley and Amanda Perrotton from Bell Howley Perrotton LLP. They discuss HMRC's Spotlight 63, which focuses on property business arrangements involving hybrid partnerships, which have recently come to the attention of HMRC.

In this episode, we discuss:

Spotlight 63 and HMRC's view of property business arrangements involving hybrid partnerships and why HMRC consider such arrangements to be fiscally ineffective
the individuals and companies for whom Spotlight 63 might be relevant
what the consequences might be for those who have participated in the type of property business arrangements referred to in Spotlight 63.

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Exploring tax from an ESG perspective with the Fair Tax Foundation

Fri, 07 Jun 2024 10:30:34 GMT

In this month's episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Paul Monaghan, Chief Executive and co-founder of the Fair Tax Foundation to discuss the growing interest in tax from an ESG perspective, and the work of the Fair Tax Foundation.

In this special episode for Fair Tax Week, Alexis and Paul discuss:

the Fair Tax Foundation and its aims
tax transparency and good governance
how organisations can become Fair Tax Mark accredited
the requirements for accreditation
key performance indicators.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

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The latest on the loan charge scandal with Matt Hall from Armadillo

Mon, 20 May 2024 13:36:29 GMT

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Chartered Tax Adviser, Matt Hall from Armadillo to discuss the latest on what is often referred to as the "loan charge scandal".

This episode considers the loan charge controversy, including:

The background to the introduction of the charge.
Those primarily impacted by the charge.
Why it remains relevant today for so many taxpayers.
What can be done to resolve the loan charge saga once and for all.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

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Changes to non-domiciliary rules with Philip Simpson KC and Ben Symons

Mon, 29 Apr 2024 12:42:10 GMT

In this episode, Alexis Armitage, RPC's Taxing Matters host and Senior Associate in our Tax Disputes team, is joined by Philip Simpson KC and Ben Symons from Old Square Tax Chambers to discuss the Government's Spring Budget and, in particular, the proposed changes that will affect non-UK domiciled individuals.

This episode covers the major changes to the UK's non-domicile regime proposed by the Government, including:

The shift from domiciled-based taxation of individuals to the new residence basis for taxation of individuals.
Transitional reliefs for current non-domiciled individuals.
The inheritance tax implications of switching from a domicile basis to a residence basis.

If you would like to discuss any of the matters raised in this episode, please contact Adam Craggs and Alexis Armitage.

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International Women's Day special – Inspiring inclusion with Tax Titan Trio

Thu, 07 Mar 2024 16:59:14 GMT

To celebrate International Women's Day 2024, we have produced a special episode of RPC's Taxing Matters podcast in which we discuss this year's campaign theme #InspireInclusion and what it means to each of our guest speakers.

RPC's Taxing Matters host and Senior Associate in RPC's Tax Disputes team, Alexis Armitage is joined by three inspirational female leaders working in tax:

Tasneem Kadiri, Tax Director for UK & Ireland at L’Oréal.

Dipti Thakrar, M&A Tax Practice Lead at Hitachi Energy.

Ashling Donnelly, Head of Tax at Trainline.

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A whistle-stop tour of the taxation of international sports and rock stars with Patrick Way KC

Tue, 20 Feb 2024 08:00:42 GMT

In this episode, RPC's Taxing Matters Host and Senior Associate in RPC's Tax Disputes team, Alexis Armitage, will be discussing the taxation of international sports and rock stars with leading silk, Patrick Way KC.

Patrick is one of the founders of Field Court Tax Chambers. He has successfully represented clients at all levels of the UK court system and has acted for both taxpayers and HMRC.

In this episode, the following will be discussed:

How HMRC treat payments when musicians sell their rights in respect of recordings and publishing rights

How the worldwide sponsorship income and other worldwide income of musicians and sportspersons are taxed in the UK when they play at concerts or appear at sporting events in the UK

IR35 – an update on where we are after the Kaye Adams / Atholl House case

The latest position of HMRC in relation to image rights contracts; and a brief discussion on the taxation of agents' fees (a further podcast will follow from our very own Michelle Sloane on this topic in April – watch this space!).

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Exploring the World of AI with Olivia Dhein

Mon, 29 Jan 2024 11:17:43 GMT

In this episode we discuss the hot topic of artificial intelligence. We will consider what is AI, what is a large language model and how does it work, what can AI do and not do at the moment as well as some of the potential effects AI might have in the tax world. We also take a look at the recent Tax Tribunal decision in Harber v HMRC [2023] UKFTT 1007 (TC), in which false case law was generated by AI and innocently relied upon by the taxpayer and how the Tribunal dealt with this.

We are delighted to be joined by our very own expert Olivia Dhein. Olivia is a Knowledge Lawyer at RPC. Prior to joining RPC Olivia was a Professional Support Lawyer at Lexis Nexis and before that she was a commercial disputes lawyer at Freshfields. Olivia is an expert in this dynamic and rapidly changing area.

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Tackling "Tax avoidance" this Christmas season with Sam Brodsky

Mon, 11 Dec 2023 21:18:11 GMT

As the cost of living crisis bites more than ever this year, in this special Christmas episode of RPC's Taxing Matters, we bring you some Christmas cheer by way of a light-hearted discussion of some of the potential ways you may be able to reduce your tax bill. In addition, we'll also have a quick look at Santa's tax position in the run up to Christmas and whether he might be guilty of tax avoidance … or even tax evasion!

We are delighted to be joined by guest speaker Sam Brodsky. Sam is a barrister at Gray's Inn Tax Chambers and has a busy practice covering the full range of UK tax, commercial and chancery law. He is regularly instructed in the High Court and the Tax Tribunals both as lead and a specialist tax and/or property junior and most importantly, he has a great sense of humour.

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A Day in the life of a tax adviser with Jeremy Johnson

Mon, 27 Nov 2023 17:53:27 GMT

In this episode of Taxing Matters, we are joined by Jeremy Johnson, managing director of inTAX Limited. Jeremy helps clients to manage and resolve HMRC enquiries, and disclosures. Prior to joining inTAX six years ago, Jeremy worked in the tax disputes and investigations team at PwC and Grant Thornton, and before that was an inspector of taxes at HMRC.

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Why now is the right time to get to grips with your money with Ruth Handcock and Ali Poulton

Fri, 27 Oct 2023 13:51:48 GMT

In this episode of Taxing Matters, we discuss the hot topic of financial health, wellbeing and confidence. We are currently experiencing a challenging economic climate and any guidance on this important topic is very welcome.

To talk us through this subject and provide some practical guidance we are delighted to be joined by Ruth Handock, who is the CEO of Octopus Money, and Ali Poulton, who is a practising financial coach and who now works as a head coach, training and mentoring other coaches across the Octopus Money team.

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Sanctions Spotlight Session with Alice Kemp

Mon, 25 Sep 2023 14:19:31 GMT

In this episode of Taxing Matters, we are handing over the podcast baton and introducing our new host Alexis Armitage, who is a Senior Associate in RPC's Tax Disputes Team. We couldn’t think of any better way to say our final goodbyes to the fabulous Alice other than by putting her in the hot seat to discuss the topic of the moment, sanctions.

Alice is an employed barrister at RPC who specialises in sanctions and fraud investigations and litigation conducted by the various UK regulatory bodies. She has advised financial institutions, corporates and charities on the sanctions impacts of transactions particularly those involving the complex sectoral and trade sanctions regimes, advised on the application of export control provisions to international trade and assisted with queries around listing and delisting of individuals under the UK, EU and UN sanctions regimes.

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Let's talk VAT security notices with Joshua Carey

Fri, 18 Aug 2023 12:57:53 GMT

One of the things that becomes clear over the course of one's career is that enforcement trends are important for businesses to be aware of. It is important to notice, not just the macro trends like sanctions compliance and fraud enforcement, but also smaller trends; campaigns against particular tax risks and the relegation of certain information gathering powers to relative obscurity.

In this episode of Taxing Matters, we discuss the rise in one of the smaller trends, the resurgence of the use of the VAT security provisions. These provisions aren't new, but they are experiencing an upswing and can have far reaching consequences for businesses, and a number of traps for the unwary.

Joining us is Joshua Carey, an expert tax barrister at recognised repository of tax excellence, Devereux Chambers. Josh, who was recently named a Rising Star by legal directory, the Legal 500, specialises in tax, public and judicial review, commercial litigation, civil and criminal fraud, and business crime - and did we mention tax?

Josh gives us his top tips for making sure you know what to do – and not do – if you're faced with a VAT security notice.

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The power of language when talking about tax with Kirstie Skates

Mon, 17 Jul 2023 10:45:56 GMT

Have you ever wondered about the language we use when we talk about tax? And does that language influence or betray how we feel about tax as individuals or as a society? It turns out it is a hot topic of discussion.

In this episode of Taxing Matters, we are delighted to be joined by Kirstie Skates, founder of “Illume Linguistics”. Illume Linguistics are a team of linguistics experts who specialise in using techniques from language science to analyse organisational customer and community discourse. Their focus is on identifying the underlying assumptions and gaps in understanding that get in the way of effective communication between organisations and the people they want to connect with.

Kirstie has worked in the field of organisational and individual behaviour change for over 20 years and has always been fascinated by the power of language to reveal people's beliefs about themselves, others, and the world around them.

We discuss, in this episode of Taxing Matters, Kirstie's recent research paper - published in December last year - on the fascinating topic of how tax is framed by the private client industry and linguistic analysis which was commissioned by the “Good Ancestor Movement”.

References

December 2022 Report by Kirstie Skates- How is tax framed by the private client industry?

Good Ancestor Movement who commissioned the work

https://www.linkedin.com/company/good-ancestor-movement/

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Wealth Tax & Wealth Inequality with Dr Ben Tippet

Fri, 02 Jun 2023 11:23:23 GMT

As questions of economic resource allocation push to the forefront of the national consciousness there has been a rise in the number of people calling for either new taxes or wholesale tax reform. This has been mirrored by the increase in lobby groups such as Patriotic Millionaires UK a lobby group of high net worth and ultra-high net worth individuals who feel that they should be doing more. There are also a number of groups who are calling for a lower upper tax bracket in order to stimulate the economy.

In this episode of Taxing Matters, we discuss wealth tax and whether such a tax should be introduced? We are delighted to be joined by Dr Ben Tippet.

Ben is a lecturer in economics based at the Institute of Political Economy Governance, Finance and Accountability at the University of Greenwich and author of the thought provoking book 'Split Class Divides Uncovered'. Ben’s research focuses on pertinent questions around wealth inequality, housing, debt and political economy. He has been published in the Guardian, Opened Democracy and the BBC World Service.

References

Revenue potential of UK wealth tax

Impact of wealth tax on investment

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Women in Tax Network: Connecting Professionals

Tue, 04 Apr 2023 09:00:12 GMT

We all know the benefits which networking and creating a supportive space in which to learn and ask questions can bring to our individual practices. Today we want to highlight one of the award-winning networks which is helping to develop networking opportunities within tax together with the benefits it can bring as highlighted by two of its amazing committee members.

In this episode of Taxing Matters, we discuss the Women in Tax network and the benefits it can bring for all professionals. We are joined by its Chair Tasneem Kadiri and Events Committee Member, Alexis Armitage.

In addition to putting her excellent organisational skills to use for the Women in Tax network, Alexis is also a solicitor in RPC's Tax, Financial Crime and Regulatory team, where she specialises in advising both individuals and corporate clients on a broad range of contentious tax issues involving direct and indirect taxes. Tasneem is a chartered accountant and chartered tax advisor with experience in both practice and industry. Currently, in addition to chairing Women in Tax, Tasneem is responsible for managing all the UK and Ireland tax affairs for L'Oréal.

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Shifting the dial on ESG

Tue, 07 Mar 2023 11:32:12 GMT

For international women's day we have produced a special episode of our Taxing Matters podcast, in which we discuss macro trends in ESG and gender diversity at work, the meso-level changes within organisations and the micro changes on a personal level talking through trends in ESG. Did we lose momentum during Covid? Do we still have the emphasis in the right places? And what can each of us do to shift the dial?

We are joined by Kelly Thomson and Phoebe Waters who talk about moving the dial – making a change in your own behaviour that helps to create overall change at an organisational or societal level.

Phoebe is a Chair of Female Fraud Forum, delegate to the United Nations' Commission on the Status of Women and visiting lecturer on gender equality at Cambridge University

Kelly is a partner in RPC's Employment, Engagement and Equality team. She leads RPC's ESG strategy and is a co-host of the equality podcast The Fix, with Michelle King.

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Unravelling the differences between the UK & US tax systems

Mon, 06 Feb 2023 11:01:27 GMT

Whilst different tax systems try to reach similar outcomes, they often achieve that via different routes and by applying different methodologies, but what do you need to bear in mind when considering UK and US cross-border matters?

In this episode of Taxing Matters, we are joined by Alex Jones and Graeme Privett, who share their insights and views on how the US and UK are less similar than people might think and how this could lead well-meaning taxpayers into avoidable difficulties.

Alex and Graeme are both Partner's at Rawlinson & Hunter. Alex has 30 years experience in US and UK personal tax, providing complex planning and assistance to high-net-worth individuals whilst Graham advises on a wide range of personal tax issues for both UK and non-UK domiciled individuals.

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Witness Familiarisation

Mon, 12 Dec 2022 11:45:49 GMT

Taking the witness stand can be challenging and nerve-wracking; more persuasive evidence is likely to be given when a witness has properly prepared for the occasion.

In this episode of Taxing Matters, we demystify witness familiarisation and what is permitted by the tax tribunals and the courts with Dr Penny Cooper.

Dr Penny Cooper is a barrister who provides a specialist witness familiarisation and preparation service.

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Research and Development tax relief

Fri, 09 Sep 2022 15:54:26 GMT

In this episode of Taxing Matters, we discuss the role of R&D tax relief, how to qualify for the relief, how to stay compliant, some common abuses of the system and some of the recently proposed reforms.

We are joined by Sarah Scala, Head of Tax Dispute Resolution, and Caroline Walton, Head of Innovation Relief, at Claritas Tax.

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The Case of The Missing Crypto

Fri, 20 May 2022 16:47:41 GMT

What should you do if your crypto is stolen?

If you've invested in cryptocurrency your investment can be an increasing target for fraud, and it can be difficult to recover funds when this happens.

In this episode of Taxing Matters, we discuss practical steps to take if your crypto has been stolen, recent crypto fraud case studies, search and seizure orders and enforcement for crypto assets with Chris Whitehouse.

Chris Whitehouse is a senior associate at RPC who advises on crypto-related disputes.

Show references

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The Asset Tracing Investigator: Following the money

Fri, 06 May 2022 16:33:16 GMT

Have you ever wondered what happens behind the scenes of an investigation?

In this episode of Taxing Matters, we discuss the role of the investigator in asset tracing, how they support clients and add value, and some common misconceptions about the traditional image of investigators, with Phoebe Waters.

Phoebe is an asset tracing specialist and Chair of the Female Fraud Forum. She is also a champion of women in the industry. Winner of Management Today’s 35 Women under 35 2021.

References

· The Female Fraud Forum

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Challenging tax avoidance

Fri, 22 Apr 2022 16:53:28 GMT

The tax gap refers to the difference between the amount of tax that should, in theory, be paid to HMRC, and what is actually paid. To help narrow this gap, HMRC has been granted a number of powers over the years, including those aimed at tackling tax avoidance.

The Finance Act 2022 provided HMRC with additional powers to enable it to proactively clamp down on promoters of tax avoidance schemes, challenge misleading information and 'name and shame' connected individuals.

In this episode we ask Danielle Ford, Head of Tax Disputes & Resolutions at haysmacintyre, how HMRC will use these new powers, the key issues that may arise and the impact they could have.

References

· Measuring tax gaps 2021

· Rise in HMRC demands for information from professional services firms on suspected tax evading clients

· Tax fraud: The rise of the professional enabler

· Unpaid taxes: the ‘tax gap’

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Does the Economic Crime Act really have teeth?

Fri, 08 Apr 2022 16:22:55 GMT

In March 2022, the Economic Crime Transparency and Enforcement Act came into force after it was fast-tracked through Parliament in response to urgent calls for the UK's economic crime laws to be tightened.

The new legislation introduces further sanctions powers and aims to tackle financial crime by revealing the identities of overseas beneficial owners of UK property. We asked Tom Godfrey whether this important piece of legalisation is likely to be effective and achieve its aim?

Tom, a barrister at 23ES, is a recognised leader in the field of corporate crime and has been instructed on some of the most complex financial crime cases of recent times.

References

· Tackling economic crime and sanctions evasion

· Corporate Crime Reform: A comparative guide

· The complicated question of corporate criminal liability

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What can HMRC do with your information?

Fri, 25 Mar 2022 17:12:19 GMT

In previous episodes we have discussed the myriad of ways HMRC collects information on individuals and businesses. Whether through international agreements, information provided on a voluntary basis, as a consequence of a legal duty to report, or through its information gathering powers, the Revenue holds an abundance of information relating to taxpayers.

In this episode, we discuss the important question of what exactly can HMRC do with your information?

Keziah Mastin joins us to help shed light on this important issue and explain the powers HMRC has when dealing with taxpayer information – and what restrictions apply. Keziah is the newest member of our Tax and Financial Crime team having recently joined from HMRC's Solicitor's Office, where she specialised in a variety of things including strategic litigation, international trade and customs policy.

References

· Connecting the dots

· The Common Reporting Standard: An HMRC game changer?

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Cum-Ex: a multi-billion tax trading scandal

Fri, 11 Mar 2022 16:31:00 GMT

In a much-anticipated podcast we revisit the multi-billion tax trading scandal known as Cum-Ex, and consider recent developments and discuss why this rapidly expanding cross-border tax fraud remains of interest 5 years after it was first exposed.

With so many twists and turns since Bloomberg journalist Donal Griffin first covered the Cum-Ex fraud on Taxing Matters episode 12 back in December 2020, we are delighted to be joined by barrister David Stern, to discuss recent developments.

David is Joint Head of the Regulation and Business Crime Practice Group at 5 St Andrews Hill Chambers, and is currently retained by several clients with exposure to the on-going Cum-Ex trading investigations and is a leading expert in this specialised area.

References

· Cum-Ex - probably the biggest tax scandal you've never heard of

· The Cum-Ex trading scandal: What are the implications for the UK? | Articles | 5SAH

· PRIN 2.1 The Principles - FCA Handbook

· COBS.pdf (fca.org.uk)

· Market Watch 52 (fca.org.uk)

· Criminal Finances Act 2017 (legislation.gov.uk)

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The legal landscape of crypto fraud

Fri, 25 Feb 2022 17:25:02 GMT

In a follow up to the episode Blockchain: Revolutionary technology… or the perfect opportunity for fraudsters, we are delighted to be joined by Michael Goodwin QC to delve deeper into the legal landscape of crypto fraud. Michael, a highly regarded Silk at Red Lion Chambers, is an eminent white collar crime practitioner described by Legal 500 as a “serious heavy-hitter in criminal fraud".

While crypto is increasingly challenging traditional finance systems and fast becoming a mainstream alternative, it has also provided an opportunity for criminal behaviour. With increasing numbers of people falling victim to crypto fraud, this episode focuses on the criminal law in this important area of the law.

References

· Crypto Fraud and Asset Recovery Network

· HMRC internal manual: Cryptoassets

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Supporting mid-sized businesses in a challenging landscape

Fri, 11 Feb 2022 17:28:36 GMT

In the first Taxing Matters episode of 2022, we are delighted to be joined by special guest Margaret Mousley, Deputy Director at HMRC. While Margaret now heads up HMRC’s Mid-Sized Business division, her career has spanned over 18 years across key compliance roles within the Revenue.

With the vast array of potential risks and tax pitfalls now facing mid-sized businesses (MSBs), Margaret discusses how her team is investing in enhancing its customer service offerings to further improve the quality of the service it provides to MSBs.

References

· Making Tax Digital for VAT as an agent: step by step

· Get help with a tax issue as a mid-sized business

· HMRC Profit Diversion Compliance Facility

· HMRC internal manual: Cryptoassets

· Taxing Matters: Clearer lines of communication

· Taxing Matters: Tax fraud - The rise of the professional enabler

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Reputation management: the vital difference between reacting and responding

Fri, 17 Dec 2021 17:33:58 GMT

Warren Buffet once quipped, "It takes 20 years to build a reputation and only 5 minutes to ruin it". The potential impact of reputational damage can be significant during litigation, or a commercial dispute. Understanding when to react and how to respond, can make all the difference.

From media strategies to risk mapping, Stuart Leach joins us on this episode to explore how you can best protect your business's public image and reputation, should that become necessary.

An advertising executive turned barrister turned reputation advisor, Stuart now heads up the Litigation & Disputes team at Montfort Communications.

References

· RPC ReAssure

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Blockchain: Revolutionary technology… or the perfect opportunity for fraudsters

Fri, 03 Dec 2021 17:03:47 GMT

In recent times it seems that the word crypto, and the underlying blockchain technology associated with it, is on everyone’s lips. From Elon Musk's effect on the price of Bitcoin to non-fungible tokens in the art world, the debate rages over whether blockchain will revolutionise the world or lead to the dismantling of the existing order.

Many critics have focused on the potential opportunities it might create for fraudulent behaviour. Helping us sort fact from fiction we are delighted to be joined by three of the founding members of the Crypto Fraud and Asset Recovery Network (CFAAR); the world’s first global network consisting of, amongst others, lawyers, accountants and asset recovery specialists.

Carmel King is a Director at Grant Thornton who specialises in asset tracing and recovery for victims of fraud; Dan Wyatt is a Partner at RPC and Chris Whitehouse is a Senior Associate at RPC – both advise on a range of civil and cyber fraud matters, including on the recovery of misappropriated assets.

References

· Crypto Fraud and Asset Recovery Network

· AA v Persons Unknown

· Wang v Darby

· Fetch.AI v Persons Unknown

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Clearer lines of communication

Fri, 19 Nov 2021 16:50:57 GMT

With increasing pressure on HMRC to collect more tax with less resource, it is more important than ever to communicate effectively with HMRC. In this episode we are joined by Annis Lampard, who leads the tax disclosure and transparency team at Deloitte, to discuss the benefits of a more open dialogue with the Revenue and the steps you should take to improve lines of communication.

With a particular focus on wealthy individuals and mid-size businesses, Annis provides practical advice for taxpayers and their advisors and shares her tips on how to avoid misconceptions, and correct misunderstandings in order to identify what it is HMRC requires and thereby minimise the risk of a formal dispute arising.

References

· Litigation and Settlement Strategy

· Research Report: tax compliance behaviour among the wealthy

· Taxing Matters: Alternative Dispute Resolution

· The Common Reporting Standard: An HMRC game changer?

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Corporate Crime Reform: A comparative guide

Fri, 05 Nov 2021 17:04:40 GMT

In a much anticipated follow up to our previous episode on the Law Commission's consultation on the law of corporate crime in the UK, we are delighted to be joined by Dr Robin Lööf to dive a little deeper into the key issues at the heart of this important topic.

Robin considers the various options for reform currently being debated and discusses whether, in practice, the law of corporate criminal liability does need to be reformed in order to achieve its intended purpose. Robin draws on his extensive understanding of legal frameworks in other jurisdictions (including the US, France and Italy) to provide a fascinating comparative guide to corporate criminal liability.

References

· Reform of Corporate Criminal Liability – Considerations in view of the Law Commission Options Paper

· The complicated question of corporate criminal liability

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Navigating your career: In conversation with Jack Bonehill

Fri, 22 Oct 2021 16:10:09 GMT

In this episode, we are delighted to be joined by fellow tax podcast host Jack Bonehill, the man behind the fantastic Tax Professionals Podcast series.

Through his podcast, Jack aims to provide easily digestible information to tax professionals to help them progress and develop their careers.

We put Jack in the hot seat and pick his brain on the suite of complimentary resources he has created to assist tax professionals, and discuss his own career journey. Jack also shares some of the excellent advice he has provided to professionals over the years.

References

· Tax Professionals Podcast

· Tax Professionals free course

· "Most popular exam help"

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Sneak peek… Unspoken Giants: A new podcast series

Fri, 08 Oct 2021 15:37:46 GMT

From the team behind Taxing Matters, we are delighted to be able to share with you a short preview of our newest podcast – Unspoken Giants: International Financial Institutions.

Launching soon, in a world first the Unspoken Giants series will bring together senior leaders from the largest International Financial Institutions (IFIs) and Multilateral Development Banks (MDBs) to discuss their fight against the cancer of corruption and will highlight how this impacts those involved in the projects they fund. From the World Bank and EBRD to the Asia Infrastructure Investment Bank and the Global Fund, each episode will provide unique insight into how each IFI operates and the powers they have to investigate and sanction.

If you would like to ensure you are alerted once the episodes are released, or would like to discuss International Financial Institutions further, please contact unspokengiants@rpc.co.uk.

Show resources

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Connecting the dots

Fri, 24 Sep 2021 17:00:29 GMT

In a world of increasing digitisation, globalisation and remote working, now more than ever taxpayers are starting to ask "how are HMRC going to find out?".

In this episode, Jay Sanghrajka, international tax partner at Price Bailey, joins us to explain how HMRC might find out!

Historically, HMRC's investigations were often commenced as a consequence of discrepancies in a taxpayer's record keeping or information being received from disgruntled employees or former spouses. Now, at the heart of HMRC's counter-evasion efforts lies a powerful computer program called “Connect” with 90% of enquiries based on the information it generates.

References

· What is "Connect"?

· HMRC’s Connect computer and investigations

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Lockdown thoughts: the evolution of HMRC and its increasing powers

Fri, 10 Sep 2021 15:25:50 GMT

Given the complexity and, at times, lack of clarity in our tax system, concerns have been raised about the extent of HMRC's powers, particularly regarding the range of penalties that can be imposed for innocent mistakes, and the severity of penalties that can be imposed in relation to offshore matters.

There's no 'quick fix' but it is important that there is effective oversight of HMRC.

In this episode we are delighted to be joined by David Goldberg QC of Gray's Inn Tax Chambers, who in the world of tax law needs no introduction. He shares his deep understanding of the evolution of HMRC's powers and discusses whether there needs to be proper oversight of the exercise of those powers in order to ensure fairness within the system.

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The tax tribunals: the next 10 years

Tue, 31 Aug 2021 15:00:18 GMT

Twelve years on from the seismic changes to the UK tax appeals system that introduced the First-tier Tribunal and the Upper Tribunal, the Tax Law Review Committee (TLRC) has published its Report "The tax tribunals: the next 10 years".

Intended to be a review of how the tax tribunal system has operated and providing recommendations for changes required for the next 10 years, the Report considers a number of important issues, including access to justice, unacceptable delay and certain tactics deployed by HMRC in an attempt to game the system.

In this episode, we are delighted to be joined by Dr Michael Blackwell, TLRC committee member and Associate Professor of Tax Law at the London School of Economics, to discuss the Report's findings.

References

· The Tax Law Review Committee

· The tax tribunals: the next 10 years

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The vexing question of corporate criminal liability

Fri, 13 Aug 2021 15:57:20 GMT

Many commentators have questioned whether the law relating to corporate criminal liability is still fit for purpose or whether it is due a significant overhaul. The Law Commission has been asked by the Ministry of Justice, Home Office, Department for Business Energy and Industrial Strategy, HM Treasury and the Attorney General's Office, to consult on how the law of corporate criminal liability functions and how, if at all, it should change.

The Law Commission is inviting anyone with an interest in this area to make their voice heard by 31 August 2021 at Corporate criminal liability Consultation.

With the potential for significant change on the horizon, we are joined by David Allan, a criminal law reform lawyer with the Law Commission who is working on the corporate criminal liability project, to discuss how the law currently operates and some of the suggested changes to corporate criminal liability that have been put forward.

References

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Lockdown, tax residency and the law of unintended consequences

Fri, 30 Jul 2021 18:25:49 GMT

A little over 18 months ago and the idea of government enforced national lockdowns would have seemed like a very unlikely Orwellian concept indeed and yet, since then, over 100 countries have instituted at least one lockdown, affecting billions of people worldwide.

In this episode, we are joined by Price Bailey's Nikita Cooper to discuss the myriad of unintended consequences lockdowns have had on tax residency for individuals and corporations. From employees stuck abroad while visiting relatives to senior management inadvertently changing the corporate residency of their companies, we explore some of the practical implications.

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Dawn of a new era: predicted increase in dawn raids!

Fri, 16 Jul 2021 17:37:47 GMT

With financial pressure mounting on the Government, and with an additional 1000 new fraud investigators announced in the last budget, many expect the frequency of HMRC dawn raids to increase considerably.

From HMRC cars used as battering rams to offices swarmed by bulletproof vest wearing investigators (both real events albeit not typical!), we are joined by Michelle Sloane in this episode who shares with us some of the many experiences she had had when attending dawn raids. In an adrenaline fuelled and extremely stressful dawn raid scenario, you need to understand your rights, the process and how to ensure you take the right action on the day.

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Playing a winning hand: dealing with an HMRC enquiry

Fri, 02 Jul 2021 15:40:26 GMT

In this episode of Taxing Matters we are joined by John Cassidy, a Tax Resolutions Partner at accountancy firm Crowe UK. A tax veteran of over 25 years, when it comes to tax investigations, what John hasn't experienced, written about or lectured on isn't worth knowing!

In this extremely practical discussion, John takes us through the lifecycle of a HMRC enquiry using real-life case studies to highlight actionable insights and common mistakes. From challenging misconceptions to revealing trends in behaviour from the Revenue, John's insights may prove invaluable the next time you have to deal with an HMRC enquiry.

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Ashbolt and Arundell: challenging search warrants

Fri, 18 Jun 2021 16:25:37 GMT

In this latest episode of Taxing Matters we take a closer look at the recent case of Asholt and Arundell v HMRC, which involved a challenge to the lawfulness of a search warrant which had been executed by HMRC.

Leading barrister Jonathan Fisher QC, who has over 30 years of experience in financial fraud and tax cases and founder of Bright Line Law, joins us to discuss how you can challenge the lawfulness of search warrants and some of the practical difficulties involved in such a challenge.

We consider the process of obtaining a search warrant, what materials fall within the description of the warrant, and the specific powers granted to HMRC officers. Jonathan provides expert insight into how to successfully challenge search warrants by way of judicial review.

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Shifting sands: insuring tax risks

Fri, 04 Jun 2021 16:57:29 GMT

In a special cross-over episode with our sister podcast Insurance Covered, this episode looks at the growth in popularity of tax liability insurance.

Giles Hambly, a Tax Specialist in the Major Risks Practice at global insurance broker Gallagher joins us to explain what tax liability insurance covers, how it works in practice and why many businesses are now choosing to take it out.

From potential hidden M&A risks to future tax policy changes there are a multitude of reasons why businesses might take advantage of the protection afforded by such coverage. Given Giles' background as a former tax adviser and lawyer, before his subsequent segue into the world of insurance, Giles provides a unique insight into tax liability insurance and explains why it might have an important role to play in your business too!

Show references

Insurance Covered podcast series

Gallagher M&A practice

RPC M&A practice

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Tax fraud: The rise of the professional enabler

Fri, 21 May 2021 16:11:03 GMT

In this episode, we are joined by Simon York, Director of HMRC's Fraud Investigation Service (FIS). Created only five years ago, FIS has already secured 3,700 criminal convictions for serious fraud and protected over £25 billion in assets.

By exploiting the latest developments in virtual currencies, encrypted communications and financial systems, tax fraud is becoming increasingly complex. Simon talks to Taxing Matters about some of the key trends and how they are shaping FIS' strategic focus for the future.

In particular, Simon discusses how advice and assistance from professional enablers is becoming an increasingly vital element of tax fraud – and how FIS plan to counter it.

Show references

HMRC’s response to the rise of the enabler

The J5 website

Corporate criminal offence Taxing Matters episode

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Furlough, fraud and the FIS

Fri, 30 Apr 2021 20:42:16 GMT

Twenty episodes ago, in early summer last year, our Taxing Matters podcast focused on the newly emerging risk of furlough fraud. Now, nearly a year on (and three iterations of the Coronavirus Job Retention Scheme later) David Francis, Head of Tax Dispute Resolution at Grant Thornton, joins us to discuss this important and evolving topic.

At the outset, a key concern was whether the speed with which the Coronavirus Job Retention Scheme was set up might create a situation where innocent but incorrect, or fraudulent, claims would be submitted to HMRC. With an estimated 5 to 10% of all furlough claims, or approximately £3.5bn, falsely or incorrectly claimed, the Government has provided £100m of additional funding to HMRC's Fraud Investigation Services (FIS) to investigate suspected discrepancies.

David discusses the tools FIS have at their disposal and the action HMRC is taking to uncover fraudulent claims – and offers some pertinent advice to businesses who may have concerns about the claims they have made.

Show references

Taxing Matters: Furlough Fraud

Furlough fraud and Government clawback: managing the risk

HMRC's new powers to investigate furlough abuse

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The Trade-off: Reduced juror numbers in criminal trials

Fri, 16 Apr 2021 18:26:39 GMT

The backlog of criminal cases (especially for those relating to fraud) has increased considerably. It is reaching worrying levels resulting in administrative difficulties and substantial cost, both in financial and emotional terms.

In the past year, the number of outstanding Crown Court trials has risen by over 40% with trial dates now being fixed up to four years after the time of the alleged offence. With the delays causing significant evidential difficulties – not to mention the toll it takes on all parties who are left in limbo for prolonged periods of time – a proposal to reduce the number of jurors has been put forward as a solution to addressing the backlog.

In this episode, Professor Michael Saks joins us to discuss whether this proposal really will solve the problem, what the unintended consequences might be, and whether it is worth the trade-off.

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The Common Reporting Standard: An HMRC game changer?

Fri, 02 Apr 2021 18:00:23 GMT

With now over 100 countries signed up to the international information exchange known as the Common Reporting Standard (CRS), last year HMRC received 84 million details of bank accounts covering one in 10 UK citizens.

As CRS data is increasingly used by HRMC to identify who should be targeted for investigation and "nudge letters", it is vital that individuals and businesses understand what information is being collected and what HRMC are doing with it.

In this episode Dawn Register, Head of Tax Dispute Resolution at BDO, joins us to explain exactly what the CRS is and discuss its increasing importance for those UK residents with financial accounts and investments overseas.

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The future of judicial reviews… and what it means for your business

Fri, 19 Mar 2021 18:23:03 GMT

Described by a previous guest on Taxing Matters as “the last bastion of the citizen against the Government", the importance of judicial reviews cannot be overstated. Yet, with the Government launching an independent review into judicial reviews, could the outcome spell future limitations and curtail the rights of businesses to access this important legal challenge?

In this episode Saima Hanif QC, a barrister at 3VB, joins us to explain what this review could mean for the future of judicial reviews and, more importantly, for your business.

Saima's broad practice spans insurance, financial services and commercial litigation, but her judicial review expertise is unparalleled – having acted in one of the few successful judicial reviews of a decision made by the FCA.

Show references

Tory party manifesto

Independent Review: Terms of Reference

Taxing Matters episode: Fair's Fair – Judicial Review and Tax Disputes

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Taxing Matters: International Women's Day Special

Sun, 07 Mar 2021 23:00:07 GMT

March 8th is International Women's Day, and to mark the occasion this episode of the Taxing Matters podcast features five empowering women who have all strived to encourage diversity and inclusion in the workplace.

Our guest speakers all come from very different backgrounds and include a global tax correspondent at the FT, a former Tax VP at Sony and the owner of a successful consulting group. They each share the challenges they have faced at work and address a range of topics including juggling family life, being overlooked and suffering imposter syndrome.

Show references

International Women's Day

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Private prosecutions: an essential part of your tax toolkit

Fri, 19 Feb 2021 18:39:32 GMT

We are experiencing a surge in economic crime – the National Crime Agency estimates fraud alone costs UK businesses around £140 billion a year. With the CPS, the SFO, and other prosecutors barely able to scrape the tip of the iceberg, many businesses have turned to private prosecutions to recoup losses and protect their reputation.

In this episode we are delighted to be joined by leading expert William Boyce QC, a barrister at QEB Hollis Whiteman Chambers, to give us a masterclass in private prosecutions and how they might be relevant to your business.

William is a committee member of the Private Prosecutor's Association and acted for the private prosecutor in the largest private prosecution to date brought by a private individual to date.

Show references

Code for Private Prosecutors

RPC Private Prosecutions

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Sanctions in a post-Brexit landscape

Fri, 05 Feb 2021 17:02:40 GMT

From the 1st January 2021 the new UK sanctions framework officially came into force under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA). Notably, SAMLA was one of the first of the first Acts passed as a direct result of Brexit.

In this podcast episode, we are joined by guest speaker Alex Haines, a Barrister at Outer Temple Chambers specialising in international law, business crime and sanctions. Alex shares his considerable insight on sanctions, how they affect trade and the changes SAMLA will now bring about.

Show references

The Association of Certified Sanctions Specialists

OFSI guidance

Smith, Owen, and Bodnar on Asset Recovery – Criminal Confiscation and Civil Recovery

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What "winning on a technicality" really means in disputes with HMRC

Fri, 22 Jan 2021 17:54:12 GMT

In this episode, we are joined by Taxing Matters podcast returnee, Harry Smith, to give us a crash course in procedural arguments in the context of a dispute with HMRC – and why they are sometimes referred to unfairly as "technicalities".

Show references

Mosson v Revenue & Customs [2020] UKFTT 359

HMRC v Tooth [2019] EWCA Civ 826

Credit Suisse Securities (Europe) Ltd and others v HMRC [2020] UKFTT 86

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The new corporate criminal offence of failure to prevent tax evasion

Fri, 08 Jan 2021 14:59:16 GMT

In this episode, we are joined by Sam Dean, who spearheads HMRC's campaign to raise awareness of the corporate criminal offence of failure to prevent tax evasion.

With this being the first "fail to prevent" style offence dealt with by HMRC, podcast host, Alice Kemp, quizzes Sam on what exactly this means, where your business may be at risk of liability and what you can do to prevent that from happening.

Show references

HMRC guidance

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CumEx: probably the biggest tax scandal you've never heard of

Fri, 18 Dec 2020 18:52:37 GMT

In this episode, we are joined by Bloomberg finance reporter Donal Griffin. For the past 18 months Donal has been following the development of the multi-billion tax trading scandal known as CumEx.

While you may well have heard of financial scandals like LIBOR rigging and FX market manipulation, CumEx is probably the biggest scandal that you've never heard of.

From billions of Euros at stake to widespread investigations into major financial institutions and explosive court testimony, this story really has it all!

Show references

Barclays unit - May 2019

Landmark Cum-Ex trial - September 2019

Arrest and extradition of Henry Gabay - July 2020

'Tip of the Iceberg' for Cum-Ex arrests - July 2020

Sanjay Shah speaks! - October 2020

ICAP the 'Spider' in the Cum-Ex web - November 2020

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Taxing Matters: The impact of the loan charge with Keith Gordon

Fri, 04 Dec 2020 17:33:25 GMT

In this episode, Keith Gordon joins Alice Kemp to discuss the Loan Charge; a topic very dear to his heart and one that has had a devastating impact on many who have been victims of schemes.

Keith is a barrister at Temple Tax Chambers, and before qualifying to the Bar, was a Chartered Accountant and a Chartered Tax Adviser. He brings this rounded tax experience to bear in this episode, charting the potted history of the loan charge and shining light on the worrying way HMRC has treated taxpayers' rights.

Content warning: Unfortunately, the loan charge has led to family breakup, divorce, and even suicide for some victims, and this episode discusses that impact.

If you have been affected by any of the issues raised or that you are unable to cope, text ‘LCAG HELP’ to 81025 and a member of the Loan Charge Action Group team will call you back.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode.

If you would like to discuss the issues raised in this episode, please contact

taxingmatters@rpc.co.uk.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

Show references

Low Incomes Tax Reform group

Loan Charge Action Group

NHS Suicide services

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Taxing Matters: An interview with the President of the First Tier Tribunal

Fri, 20 Nov 2020 16:27:03 GMT

Welcome to the Taxing Matters podcast. In this series we review land-mark cases and key tax developments and discuss the commercial impact they could have on your business.

In this episode, we are joined by a very special guest; Judge Sinfield, President of the First Tier Tribunal Tax Chamber (FTT). Judge Sinfield shares his impressive knowledge of the inner workings and intricacies of the tax tribunals, including little known facts like the FTT deals with appeals concerning MPs' expenses!

Alice Kemp and Judge Sinfield also discuss:

What tax tribunals actually are, their function and scope, and how they work;
How tax tribunals differ from the 'normal' civil process;
What you need to have in mind when starting an appeal to the FTT; and
The impact of COVID-19 and lockdown on the tax tribunals.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode.

All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

If you would like to discuss any of the issues raised in this episode, please contact

taxingmatters@rpc.co.uk.

As ever, a huge thank you to our miracle working producer, Mary Mitchell, and Josh McDonald, the man who solves all problems before they arise.

Our music is composed and produced by musical genius Andrew Waterson.

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Taxing Matters: Top COP9 tips in the era of furlough fraud

Mon, 09 Nov 2020 14:53:48 GMT

Welcome to the Taxing Matters podcast. In this series we review land-mark cases and key tax developments and discuss the commercial impact they could have on your business.

As we head into a second lockdown, it's an apt opportunity to consider how HMRC might use the Code of Practice 9 (COP9) process in relation to alleged furlough fraud which is likely to give rise to quite a lot of COP9s.

In this episode, Adam Craggs, shares his top tips and sheds light on major errors when contemplating, or going into, the COP9 procedure. Alice and Adam also discuss:

the kind of cases where HMRC usually consider using the COP9 process;
why a taxpayer should, or shouldn't, accept the Contractual Disclosure Facility route;
typical outcomes for a taxpayer who opts to engage in the COP9 process; and
consequences for those who don’t properly engage in the process and withhold information.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode. All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

If you would like to discuss any of the issues raised in this episode, please contact taxingmatters@rpc.co.uk.

As ever, a huge thank you to our miracle working producer, Mary Mitchell, and Josh McDonald, the man who solves all problems before they arise.

Our music is composed and produced by musical genius Andrew Waterson.

Hosted on Acast. See acast.com/privacy for more information.

Taxing Matters: A handy guide to appeals

Mon, 26 Oct 2020 20:13:23 GMT

Welcome to our Taxing Matters podcast. In this series we review land-mark cases and key tax principles and discuss the commercial impact they could have on your business.

In this episode, following on from our episode on judicial reviews, we take a look at another key tool in the tax payers arsenal – the appeal. Costa Christofi provides practical tips on the steps involved in appealing an HMRC decision.

Costa's insights into the appeal process covers topics including:

· What kinds of decisions are appealable;

· Tight timeframes and what to do if you miss one;

· Evidence that should be collected to rely on at a hearing; and

· The impact of COVID-19 and lockdown on hearings.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode. All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

If you would like to discuss any of the issues raised in this episode, please contact taxingmatters@rpc.co.uk.

Show resources

Judicial reviews episode

Tax Take

As ever, a huge thank you to our miracle working producer, Mary Mitchell, and Josh McDonald, the man who solves all problems before they arise.

Our music is composed and produced by musical genius Andrew Waterson.

Hosted on Acast. See acast.com/privacy for more information.

Taxing Matters: Predicting the tax world of the future

Fri, 09 Oct 2020 18:56:59 GMT

Welcome to our Taxing Matters podcast. In this series we review land-mark cases and key tax principles and discuss the commercial impact they could have on your business.

In this episode, we ask Andrew Hubbard, Editor-in-chief of Tolley's Taxation Magazine, to gaze into his crystal ball and predict the direction of travel for the UK's tax system.

In discussing recent trends, his musings on future developments include:

1. the possibility of real time tax administration in the digital world;

2. whether the balance of power has swung in favour of the State; and

3. why the Revenue may now have greater confidence to take on bigger projects.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode. All information is correct at the time of recording. Taxing Matter is not a substitute for legal advice.

If you would like to discuss any of the matters raised in this episode, please contact taxingmatters@rpc.co.uk.

As ever, a huge thank you to our miracle working producer, Mary Mitchell, and Josh McDonald, the man who solves all problems before they arise.

Our music is composed and produced by musical genius Andrew Waterson.

Hosted on Acast. See acast.com/privacy for more information.

Taxing Matters: Fair's Fair – Judicial Review and Tax Disputes

Fri, 25 Sep 2020 17:24:30 GMT

Welcome to our Taxing Matters podcast. In this series we review land-mark cases and key tax principles and discuss the commercial impact they could have on your business.

In this episode, we talk about Judicial Review, often ignored, sometimes misused, frequently misunderstood, especially in the context of tax disputes, in the right case, it remains an important part of the taxpayer's arsenal.

Robert will take us thought:

- when to consider judicial review;

- tactical considerations when doing so; and

- why he thinks that judicial review fulfils such an important democratic and constitutional role.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode. All information is correct at the time of recording. Taxing Matter is not a substitute for legal advice.

If you would like to discuss any of the matters raised in this episode please contact taxingmatters@rpc.co.uk.

Show references

https://www.rpc.co.uk/expertise/services/tax/judicial-review/

As ever, a huge thank you to our miracle working producer, Mary Mitchell, and Josh McDonald, the man who actually does all the work.

Our music is composed and produced by musical genius Andrew Waterson.

Hosted on Acast. See acast.com/privacy for more information.

Taxing Matters: HMRC as a Public Authority – what does that mean?

Fri, 11 Sep 2020 16:34:42 GMT

Welcome to the Taxing Matters podcast brought to you by RPC. In this series we review land-mark cases and key tax principles and discuss the commercial impact they could have on your business.

In this episode, we talk to Harry Smith about Her Majesty’s Revenue and Customs (HMRC) as a public authority; what they can do, and, more importantly, what they can't.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode. All information is correct at the time of recording. Taxing Matter is not a substitute for legal advice.

If you would like to discuss any of the matters raised in this episode please contact taxingmatters@rpc.co.uk.

Show references:

HMRC's Litigation and Settlement Strategy

RPC's tax judicial review expertise

As ever, a huge thank you to our miracle working producer, Mary Mitchell, and Josh McDonald, the man who actually does all the work.

The music you hear was kindly written and arranged for Taxing Matters by the musical genius Andrew Waterson.

All material is copyright to RPC LLP

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Taxing Matters: Alternative Dispute Resolution with Adam Craggs

Fri, 28 Aug 2020 11:22:48 GMT

Welcome to our Taxing Matters podcast brought to you by RPC. In this series we review land-mark cases and key tax principles and discuss the commercial impact they could have on your business.

In this episode, we talk Alternative Dispute Resolution (ADR) with the man who (quite literally) wrote the book on how to use ADR to resolve tax disputes, Adam Craggs. From how ADR works in the context of tax disputes and what kinds of cases are suitable, to the Tribunal's recent Practice Statement and the impact of Covid-19 on the prevalence of ADR; we answer all of your questions.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode. All information is correct at the time of recording. Taxing Matters is not a substitute for legal advice.

If you would like to discuss any of the matters raised in this episode please contact taxingmatters@rpc.co.uk.

Show references:

HMRC's Litigation and Settlement Strategy

HMRC's Guidance Use Alternative Dispute Resolution to settle a tax dispute

Tax Chamber Practice Statement on ADR

PLC Practice Note: Alternative dispute resolution (ADR) in tax disputes (Paywall)

As ever, a huge thank you to our miracle working producer, Mary Mitchell, and Josh McDonald, the man who actually does all the work.

The music you hear was kindly written and arranged for Taxing Matters by the musical genius Andrew Waterson.

All material is copyright to RPC LLP

Hosted on Acast. See acast.com/privacy for more information.

Taxing Matters: Schedule 36 Information Notices – all squared away

Fri, 14 Aug 2020 14:14:00 GMT

Welcome to the Taxing Matters podcast brought to your by RPC; your fortnightly guide to all things tax law and tax disputes.

In this episode, we talk Schedule 36 Notices: what are they, how do they work and what should you do if you receive one? Taxing Matters host, Alice Kemp, talks to RPC Tax Disputes Associate, Alexis Armitage, about all these questions and more.

Find out:

How these Notices work;
What you can and can't be required to give to HMRC;
The formal requirements for HMRC to issue a Schedule 36 Notice; and
Top tips for what to do if you receive a Schedule 36 Notice.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode. All information is correct at the time of recording. Taxing Matter is not a substitute for legal advice.

If you would like to discuss any of the matters raised in this episode please contact taxingmatters@rpc.co.uk.

Show references:

Schedule 36 of The Finance Act 2008 (Legislation.gov.uk)

HMRC Compliance Handbook – Information Notices

HMRC Guidance – Compliance checks

Related RPC blogs:

JJ Management – Court of Appeal confirms HMRC can conduct informal enquiries

Jiminez: High Court quashes information notices issued to non-UK resident taxpayer

The Barty Party – HMRC's information notice was invalid

Newton – Tribunal confirms that "statutory records" should be narrowly construed

Anstock - Tribunal quashes penalties imposed for failure to comply with information notice

Hegarty – HMRC information notices invalid

Tribunal sets aside HMRC's Schedule 36 information notice

HMRC's unreasonable conduct leads to costs award against it

As ever, a big thank you to our amazing guest, Michelle Sloane, our producer extraordinaire, Mary Mitchell, and to Josh McDonald, the man who solves all problems before they arise.

The music you hear was kindly written and arranged for Taxing Matters by the musical genius Andrew Waterson.

All material is copyright to RPC LLP

Hosted on Acast. See acast.com/privacy for more information.

Taxing Matters: Account Freezing and Forfeiture orders

Fri, 31 Jul 2020 09:41:38 GMT

Welcome to the Taxing Matters podcast brought to your by RPC; your fortnightly guide to all things tax law and tax disputes.

In this episode, we talk to RPC tax disputes partner, Michelle Sloane, about the rise in HMRC’s use of the draconian Account Freezing and Account Forfeiture powers introduced in January 2018; what they are, how they work, and what to do if your business is affected by them.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode. All information is correct at the time of recording. Taxing Matter is not a substitute for legal advice.

If you would like to discuss any of the matters raised in this episode please contact taxingmatters@rpc.co.uk.

Show references:

https://www.rpc.co.uk/press-and-media/hmrc-ramps-up-use-of-new-account-freezing-and-forfeiture-orders/

https://www.icpa.org.uk/news/512401/HMRC-ramps-up-measures-to-tackle-suspected-criminal-activity.htm

https://www.ft.com/content/bc4128d8-8bd7-4088-aae6-8d7686e26fda (Paywall)

https://www.legislation.gov.uk/ukpga/2002/29/part/5/chapter/3B

https://www.legislation.gov.uk/uksi/2017/1297/contents/made

https://www.5sah.co.uk/downloads/download/77/nca-v-xy-judgment-pdf.pdf

As ever, a big thank you to our amazing guest, Michelle Sloane, our producer extraordinaire, Mary Mitchell, and to Josh McDonald, the man who solves all problems before they arise.

The music you hear was kindly written and arranged for Taxing Matters by the musical genius Andrew Waterson.

All material is copyright to RPC LLP

Hosted on Acast. See acast.com/privacy for more information.

Taxing Matters: Furlough Fraud

Fri, 17 Jul 2020 14:32:11 GMT

Welcome to the inaugural episode of the Taxing Matters podcast brought to you by RPC; your fortnightly guide to all things tax law and tax disputes.

In this episode, we talk to the Furlough Guru Kelly Thomson about the Coronavirus Job Retention Scheme (Furlough) and the risk of fraud.

Please see our website www.rpc.co.uk/TaxingMatters for a transcript of this episode. All information is correct at the time of recording. Taxing Matter is not a substitute for legal advice.

Show references:

HMRC powers to tackle furlough fraudsters – take action now!

COVID 19 Your workforce: What on earth is "furlough"?

COVID-19: Your workforce – furloughing - act to mitigate the risk of exposure to tax evasion offences as scheme could be open to abuse

Furlough Fraud: How to protect your business

HMRC Guidance - Check if you can claim for your employees' wages through the Coronavirus Job Retention Scheme

HMRC Guidance - Check which employees you can put on furlough to use the Coronavirus Job Retention Scheme

HMRC Guidance - Check if your employer can use the Coronavirus Job Retention Scheme

Treasury Direction 15 April 2020

Treasury Direction 20 May 2020

Treasury Direction 25 June 2020

HMRC coronavirus (COVID-19) statistics

First press release of furlough fraud arrests

As ever, a big thank you to our amazing guest, Kelly Thomson, our producer extraordinaire, Mary Mitchell, and to Josh McDonald, the man who solves all problems before they arise.

The music you hear was kindly written and arranged for Taxing Matters by the musical genius Andrew Waterson.

All material is copyright to RPC LLP

Hosted on Acast. See acast.com/privacy for more information.