United Kingdom: Tax

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Article
HMRC’s New Anti-avoidance Information Notice Powers
HMRC has introduced anti-avoidance information notices (AAINs) under Part 6 of the Finance Act 2026, granting significantly broader powers to investigate tax avoidance promotion and facilitation. These notices can target a wide network of connected persons—including directors, advisers, and intermediaries—without requiring proof that tax was lost or that arrangements were ineffective. With substantial civil and criminal penalties for non-compliance, businesses and advisers must understand who ca
United Kingdom Tax
RPC
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Article
Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases
Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.
United Kingdom Tax
M
Macfarlanes LLP
Article
Tribunal Limits HMRC's Schedule 36 Powers In Transfer Pricing Case
When HMRC issued an information notice demanding a UK subsidiary's US parent company financial statements in a transfer pricing enquiry, the First-tier Tribunal had to determine whether such documents were reasonably required and whether the subsidiary had the power to obtain them. The case examines the boundaries of HMRC's information-gathering powers and the practical limits of corporate group relationships.
European Union Tax
RPC
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