Tax Penalty and Dispute Newsletter – March 2018

March 29, 2018

By George Rowell and John Flood

George is a commercial barrister at Exchange Chambers who specialises in tax disputes, professional negligence and insolvency. He combines heavy-weight advocacy experience with in-depth tax and commercial knowledge. In the field of tax he regularly advises on VAT, IHT, CGT, employment-related taxes, and penalties. His professional negligence practice has a particular focus on claims against accountants, tax advisors and IFAs. He also as a growing specialism in insolvency and directors’ misfeasance cases, especially where there is a tax dimension such as failure of a tax avoidance scheme.

George commenced his career in-house with HMRC before moving to independent practice. He has been a member of the Attorney-General’s Regional Panel of Counsel since 2008 and appears for and against HMRC and other Government departments.

John is a retired barrister who was formerly Head of Tax Litigation at HMRC. They are the joint authors of Tax Penalties: A Practitioner’s Guide (Sweet & Maxwell, 2017), which is available for purchase here.

This edition includes:

  1. New penalties: requirement to correct offshore tax non-compliance
  2. Have HMRC established the preconditions for issuing a penalty?
  3. Reasonable excuse: late filing penalty when tax-payer has moved abroad
  4. DOTAS regime: whether arrangements are notifiable
  5. Tax-related professional negligence: adviser’s duty to warn of risk
  6. Alleged bias in tribunal

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