HM Revenue and Customs (HMRC)
2005 merger
Abuse of rights
Acting unreasonably in defending or conducting proceedings
Administration of taxes by
Administration of VAT
Advance pricing agreements
Agent authorisation
Generally
No online authorisation for VAT
One client with several agents
Right to see data
Alternative dispute resolution
Annual report
Appeals
Generally
Appeals system
Assessment
Assessment to tax
Assets Recovery Agency
Back duty investigation
Restaurant undeclared takings and unreported staff wages
Business by telephone
Business record checks programme
Centralised functions
Certificate of discharge
Application for
Determination on application for
Effect of
Potentially exempt transfers
Charity Commission for Northern Ireland, disclosure of information
Charter
Child trust funds
Claim
Responsible person, notice of decision given to
Valid, power where not made
Class 1 contributions tables
Clearance procedures
Clearances
Collection and management
Commissioners
Complaints about
Complaints against and misconduct by, Independent Police Complaints Commission (IPCC) handling functions
Complaints and misconduct by, Independent Police Complaints Commission's powers
Compliance checks
Compounding offences
Policy
Powers
Concessions, power to give statutory effect
Confidentiality, duty of
Construction industry scheme
Audits
Guidance
Contracts for supply of goods and services
Controlled foreign companies
Clearance procedure
Excluded countries list
Power to obtain information
Data-gathering powers
Agents
Appeals
Approval by tribunal
Assessment of penalties
Charities
Commencement
Compliance
Consequential provisions
Copying documents
Credit/charge cards
Crown application
Dealing in other property
Dealing in securities
Double jeopardy
Electronic stored-value payment services, providers of
Employers
Enforcement of penalties
Environmental activities
Failure to comply, penalties
General interpretation
Giving notice
Grants and subsidies out of public funds
Inaccurate information or documents, penalties
Income, assets etc. belonging to others
Insurance activities
Interest paid or credited
Investment plans
Land, payments arising from
Licences or approvals
Lloyd's underwriters
Merchant acquirers etc.
Money service business
Penalties
Petroleum activities
Purpose of
Reasonable excuse for failures
Records
Regulations
Relevant data-holders
Rents
Retention of documents
Salaries/fees/commission etc.
Securities, payments derived from
Settlements
Specifying relevant data
Statutory records
Tax, meaning
Time limits, failure to comply
Debt management issues
Decisions and appeals
Decisions etc.: reviews and appeals
Declarations
Declarations on taking office
Deduction of payments for or in respect of tax credits
Determination
Determination of codes
Collection of debt using tax code
Direction, persons treated as one
Directions
Disclosure of information for deceased asbestos claims
Disclosure to journalist of Times newspaper certain information relating to Claimants
Disclosures
Accelerated payment notices
Benefits of
Enquiries
Follower notices
General anti-abuse rule (GAAR)
Generally
Practical considerations
Prevention of discovery
Tax avoidance schemes
Discretion for an out of time claim for overpayment of tax
Disposal of property accepted in satisfaction of tax
Disputes with
Duties
Duties of care and management
Duty of promoter to provide updated information
Enforcement by taking control of goods
England and Wales
Procedure
Scotland, summary warrant
Enforcement powers
Enforcement regime
Enhanced protection claim form lifetime allowance
Appellant not aware of need or ability to make a claim until after due date
Claim made late
Generally
Reasonable excuse
Enquiries
Entertainers
Class 1 NIC
Entitled to costs incurred after refusal of Appellant to accept offer of settlement in excess of amount awarded
Entitled to costs relating to conduct prior to commencement of appeal proceedings
Errors or mistakes by
Exchange of information on direct and indirect tax
Exchange of information with Secretary of State and Northern Ireland Departments
Extra-statutory concessions
Failure to provide information under regulation 11A
Financial institutions, notices requiring information on individuals whose identity is unknown
Financial Reporting Review Panel, legal gateway between
Formation
General functions
Gross revenues
Guidance
Property rental business: non-transfer of going concerns
Schools
Social services and welfare care
Voluntary aided schools
Guidance manuals
Harmonisation of tax administration
Information and inspection powers
Penalties
Historic houses/gardens open to public managed on a commercial basis
Information
Information and inspection powers
Annual tax on enveloped dwellings
Appeals against information notices
Copying and removal of documents
Generally
Legal professional privilege
Marking business assets
Obtaining information and documents
Offences
Penalties
Premises and other property, inspection of
Recording information
Restrictions
Special cases
Third parties
Information be provided in form and manner specified
Information powers
Inheritance tax
Unpaid tax, charge on
Inheritance tax, determination of relevant matters
Inland Revenue Regulation Act 1890
Inspection powers
Inspectors of constabulary
Interest on overpayments arising from departmental error
Internal documents, discovery
Internal review procedure
Generally
Mechanics of
Nature of
Notification of appeal to Tribunal
Practical implications
Interpretation
Accounting period and corresponding accounting period
Allowable expenses
Avoided PE
Company
Connected
Designated HMRC officer
Effective tax mismatch outcome
Excepted loan relationship
HMRC
Non-UK resident
Non-UK tax
Partnership
Permanent establishment
Review period
Small or medium-size enterprise
The insufficient economic substance condition
The participation condition
Transaction and series of transactions
Treatment of a person who is a member of a partnership
UK resident
UKPE
Interpretation of law
Change of
Revised
Interpretations
Investigation, decision taken fairly and in good faith
Investigations
Inward investment support
Issues arising, appeals dependent on decisions by
Large Business Service (LBS)
Liability for costs of application
Links with business
Management
Management of social security system
Management of tax credits
Manuals
Changes made without warning
Generally
HMRC's interpretation of law
Parts excluded from public domain
Revised to replace original V series
Meaning
MG Rover administration
Mistakes, code of practice
Money laundering
Defences
Exemptions
Generally
Meaning
Practitioner's compliance with regulations
Reporting requirements
Money laundering prosecutions
National Advice Service
National heritage property
Maintenance funds, direction by HMRC
National Insurance contributions
Transfer of power to
New businesses, guidance for
Non-resident businesses inward investment support
Notice
Relevance of hardship on giving notice
Security for PAYE and NIC
Variation of notice
Notices given by
Notification and systems for recording penalties matters of administrative law outside the remit of the Tribunal
Officer's legal capacity to issue notice, loan interest relief claim
Official error
Offshore funds certification procedure, requirements
Online ready reckoner for flat-rate scheme
Order in Council, power to transfer functions by
Generally
Northern Ireland
Orders and regulations
Orders and regulations made by
Other material
Stamp duty
Paying
Penalties
Eight late payment of PAYE
Failure to satisfy the burden of establishing a prima facie case of negligence
Generally
Late filing of Company Tax (CT) returns
Late filing of individual returns
Negligently delivering a return
Policy
Compounding offences
Errors in handling change in standard VAT rate
Policy team with overall responsibility for local authorities
Power to require information
Annual tax on enveloped dwellings
Generally
Member states, tax authorities
Penalties
Regulations made by
Summary application to High Court
Powers
Application to VAT offences
Assessment, scope
Change of interpretation
Collection and management: discretion
Compounding offences
Concession: misdirection
Criminal offence
Data-gathering
Distraint
Entering premises: inspecting v searching
Equitable liability
Generally
Hardship: special cases
Information, obtaining
Investigation
Making of regulations
Money laundering
Power to take samples
Purchased life annuities
Security for VAT
Writ of assistance
Powers to call for documents
Powers to call for production of documents
Powers to obtain contact details for debtors
Powers to obtain information
Powers to seize goods belonging to supplier
Pre-disclosure enquiry
Procedure
Abuse of process
Admissibility of evidence
Amendments to returns
Appeal against closure notice
Appeal against compulsory registration for VAT allowed
Appeal against discovery assessment, HMRC not competent to make assessment and taxpayer not resident during year of assessment
Appeal against notice of amendments during progress of enquiry
Appeal against refusal of application for approval under the Alcohol Wholesaler Registration Scheme
Appeal against taxpayer information notice
Appeal not notified to HMRC before notice of appeal given to tribunal
Appeal withdrawn by appellant prior to hearing
Appellant's application for costs in complex case
Application by appellant to adjourn
Application by HMRC to amend statement of case
Application for a third party information notice
Application for admission of late appeal
Application for appellant to be awarded costs of application on grounds of HMRC's unreasonable actions
Application for barring of HMRC from proceedings on grounds of no reasonable prospect of success
Application for costs under Tribunal Procedure
Application for extension of time for requesting full findings of fact and reasons for decision refusing reinstatement of struck out appeal
Application for extension of time to apply for permission to appeal
Application for extension of time, set-aside of tribunal's decision
Application for hearing of one ground of appeal to be deferred
Application for issue, HMRC's valid discovery under Taxes Management Act 1970, s. 29(1)
Application for permission struck out for want of jurisdiction
Application for permission to notify late appeals
Application for third party disclosure
Application for unless order
Application of tribunal rules
Application that HMRC be debarred from taking part of appeal against discovery assessments
Application to admit late appeal
Application to bar respondents from taking part in the proceedings
Application to be added as party under Tribunal Procedure (First-tier Tribunal), r. 9(3), anti-avoidance legislation on transfer of assets abroad
Application to give a taxpayer information notice
Application to make late appeals
Application to notify late appeals against discovery assessments
Application to reinstate appeals
Application to set aside approval
Application to set aside decision
Application to stay 2007-08 appeal behind appellant's 2006-07 appeal due to be heard by Court of Appeal in June 2017
Application to strike out appeals
Application to strike out part of proceedings
Application to tribunal for permission to notify a late appeal
Application under Finance Act 2008, Sch. 36, para. 3 for approval of issue of information notice to third party
Applications for reinstatement of struck-out appeals
Applications for reinstatement of withdrawn appeal
Applications to amend directions for disclosure
Applications under Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (SI 2009/273), r. 17(3)
Appointment of representative
Bankruptcy of appellant
Categorisation of appeals
Claim for overpayment relief brought out of time
Claim of legal professional privilege
Company in settlement negotiations with HMRC
Compliance with BSI 812-104
Conduct of proceedings taken into account
Dealing with requests for employment histories prior to amendment to Deregulation Bill
Determination and assessment of penalties
Direct tax
Discretion
Earlier judicial review proceedings
Effect of Taxes Management Act 1970 s. 54 agreement in relation to prior tax year
Extension of time for service of costs schedule
Failure to comply with tribunal direction
Failure to determine an application made, admit new evidence or determination of issue not part of HMRC's case
Failure to particularise grounds of appeal
FTT directions to close enquiries into various returns within 30 days and 3 months
FTT proceedings should be stayed pending criminal proceedings
Grounds of privacy and relevance
Hearing in absence of appellant
HMRC's expert evidence
Identification and scope of 'conclusion' in closure notice
Information notice under Finance Act 2008, Sch. 3, para. 3
Information notice under Finance Act 2008, Sch. 36
Interaction between self-assessment enquiries, corporation tax enquiries and Finance Act 2008
Interests of justice to set aside
Jurisdiction of tribunal
Jurisdiction of tribunal in absence of prior request for HMRC to agree to late appeal
Late applications
Legal professional privilege
Letter from appellants' representative without prejudice communication
Merits of application
Need for fairness in judicial proceedings
No jurisdiction for tribunal to consider appeal, in absence of notification to HMRC
Non-appearance of appellant
Notice of appeal given by appellant
Parties agreed that decision records incorrect amount but not agreed on correction to be made
Penalty for failure to pay amount specified in accelerated payment notice (APN)
Penalty for failure to take corrective action in response to a follower notice
Penalty imposed in accordance with Finance Act 2008, Sch. 36, para. 50
Personal private residence
Preliminary issue
Public interest in proper collection of taxes
Sampling
Statement of worldwide assets and liabilities
Strike out application by respondents
Tribunal not satisfied that permission to give late notification to HMRC be granted
Use of without prejudice material disclosed during ADR hearing
Withdrawal of appeals
Property, rights and liabilities
Prosecutions office
Provision of information by introducers
Publications
Re-categorisation of earners
Reasons for non-disclosure
Records
Recovery of contributions
Recovery of tax
Reference of issues from Secretary of State
Registration helpline
Rejection of bonus claim
Remedies when things go wrong
Respective role
Returns
Revenue and Customs Prosecutions Office (RCPO)
Right to set off VAT repayment against income tax liability
Roles of HMRC and RCPO agreed
Save as the commissioners otherwise allow
Scotland, extension of powers
Secrecy declarations
Self-assessment enquiries
Set-off of credits and debits
England, Wales and Northern Ireland
Insolvency procedures
Right to be paid a sum is transferred
Settlement of tax liabilities, judicial review
Small business unit (SBU)
Small businesses, simplified cash basis for income tax and expenses
Special methods agreements with trade bodies
Stamp duty reserve tax
Accountable date
Administration of penalties
Notice of determination
Payments
Procedure for collection and recovery
Recovery or repayment of tax
Relief from accountability
Statements of Practice
Statistical information, disclosure of
Supervision of tax advisers under Money Laundering Regulations
Supplied services
Stands at exhibition and conferences
Storage of goods
Taking control of goods, England and Wales
Tax avoidance schemes, disclosure requirements
Taxpayers charter
Taxpayers' charter
Tips, gratuities, service charges and PAYE
Toolkits
Assets, repairs and improvements
Capital v revenue expenditure
Computer software
Directors' loan accounts
Franchise payments
Income tax losses
Inheritance tax, transfers on death
Interest paid, capital and revenue elements
Legal and professional fees
Newly acquired assets
Partnerships recruiting new partners, costs of
Tax returns, avoiding errors
Training courses expenditure
Website development costs
Transfer of functions to
Expenditure facilitating
Generally
Transfer pricing risk assessment
Travelling expenses, payment of
Tribunal system of appeals
Tribunals and inquiries
Tribunals system
Unclear advice, penalty for late submission
Undertakings
Unjust enrichment, restitutionary claims
Valuation of gas, election
VAT grouping
Voluntary disclosure of Swiss accounts made later
Website, unknown material on site
Withdrawal of approval of scheme
Withdrawing from appeal after receipt of new information, cost
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