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.

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

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 [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.

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

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 [email protected].

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.

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 [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.

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

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 [email protected].

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.

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 [email protected].

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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