Challenging HMRC and Police Search Warrants: Judicial Review and Legal Representation
An HMRC or police search warrant can be challenged through judicial review where it was issued unlawfully. The execution of the search, protection of privileged communications and continued retention of seized material may also require separate legal action.
US–UK Tax Liabilities: The “Special Relationship” and Double Taxation
Paying tax in the United States does not automatically discharge your UK tax liability. Equally, HMRC’s refusal of relief is not necessarily the final word. The UK–US tax treaty and domestic legislation must be applied to the particular income, taxpayer and legal arrangements.
HMRC Tax Evasion Investigations: Legal Advice and COP9
If HMRC suspects tax evasion, early specialist legal advice can help you understand the allegation, assess the evidence and decide how to respond. An investigation does not establish that you have committed an offence. Errors, disputed tax treatment and deliberate concealment require different analysis.
Umbrella Company Joint and Several Liability: What Agencies Need to Know
From 6 April 2026, the umbrella-company joint and several liability regime can expose recruitment agencies and certain other parties in a labour supply chain to liability for PAYE amounts unpaid by an umbrella company. Whether liability arises depends upon sections 61Y, 61Z and 61Z1 ITEPA 2003 and the particular contractual supply chain.
Direct Access Tax Barrister for HMRC Disputes
You can instruct Michael Paulin directly for specialist advice and representation in an HMRC dispute, without first instructing a solicitor, where your case is suitable for direct access.
SRA Compensation Fund Claims: A Complete Guide
Learn who can claim from the SRA Compensation Fund, what losses may be recoverable, how Compensation Fund applications are assessed and what to do if your solicitor has stolen money, failed to account for client funds or a law firm has closed down.
The Court of Appeal and Remuneration Trusts: Dentists and the Toothache of Tax
The Court of Appeal’s decision in Marlborough DP Ltd v HMRC represents another significant development in the evolving remuneration trust and disguised remuneration landscape. The case is particularly relevant to dentists, healthcare professionals and advisers considering settlement strategy, litigation risk and the practical implications of Part 7A ITEPA
HMRC Policy Paper: Tax Fraud Warning – Attempts to use ‘Bills of Exchange’ to Pay HMRC
HMRC has issued a tax fraud warning concerning the use of “Bills of Exchange” arrangements to purportedly discharge tax liabilities. This article considers HMRC’s latest policy position and the importance of constructive strategic engagement where taxpayers may have entered legally vulnerable arrangement
HMRC Investigations and Dubai Residents: The Reach of Schedule 36 Powers
A specialist analysis of the Court of Appeal decision in R (Jimenez) v First-tier Tribunal and HMRC and the extent to which HMRC may issue Schedule 36 Information Notices to taxpayers resident in Dubai and other overseas jurisdictions. The article examines cross-border HMRC investigations, extra-territoriality, and strategic considerations for internationally mobile taxpayers facing HMRC scrutiny.
Recent Kittel Victories Against HMRC: Taxpayers Continue to Succeed in Major VAT Fraud Appeals
Recent Tribunal decisions continue to demonstrate that HMRC’s reliance upon the Kittel principle is far from unassailable. Several substantial taxpayer victories in major VAT fraud appeals highlight the high evidential threshold HMRC must satisfy before input tax recovery may properly be denied.
Taxpayer successful in Landfill Tax Appeal: Nuttall & Anor v Revenue and Customs [2026] UKFTT 674 (TC)
A significant First-tier Tribunal decision in Nuttall v HMRC provides important guidance on the meaning of “disposal” for landfill tax purposes and rejects HMRC’s attempt to impose more than £750,000 in landfill tax and interest following the revocation of an environmental licence.
HMRC Information Notices and Remuneration Trusts: Tribunal Criticises Overreach in Schedule 36 Case
Schedule 36 Information Notice Defeated in HMRC Remuneration Trust Dispute.