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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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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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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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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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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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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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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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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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

[email protected].

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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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: 

1. What tax tribunals actually are, their function and scope, and how they work;
2. How tax tribunals differ from the 'normal' civil process;
3. What you need to have in mind when starting an appeal to the FTT; and
4. 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

[email protected].

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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