Rachel Clark

Rachel Clark on tax whistleblowing
Rachel Clark analyses the whistleblowing regime in the context of tax whistleblowers, considering the unique position of reporting to HMRC and proposing specific protections needed to safeguard the flow of important information on tax offences.
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signing official papers
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Tax whistleblowers
Speed read: Rachel Clark analyses the whistleblowing regime in the context of tax whistleblowers, considering the unique position of reporting to HMRC and proposing specific protections needed to protect the flow of important information on tax offences.
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Corporate buildings
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Confiscating from corporates
Speed read: In Crown Prosecution Service v Aquila Advisory Limited [2019] EWCA Civ 588, the Court of Appeal held that the CPS could not confiscate illicit funds from a company without having brought charges against it. The Crown had included...
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Dubai skyline
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You can run, but you can’t hide: HMRC takes the fight overseas
In R (oao Jimenez) v HMRC [2019] EWCA Civ 51, the Court of Appeal held that HMRC can issue a taxpayer notice to a UK national resident in Dubai. In doing so, it has added to the revenue’s armoury in the battle...
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Tax reporting
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Thinning the line between recklessness and wilful blindness in tax offences
Speed read: In R v Godir [2018] EWCA Crim 2294 the Court of Appeal held that recklessness was insufficient to convict the defendant of two criminal offences. However, tax practitioners should not take too much comfort from the decision as...
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Tax investigations — responding to a taxpayer notice
Speed read: In The Queen on the application of PML Accounting Limited v The Commissioners for HM Revenue and Customs [2018] EWCA Civ 2231, the Court of Appeal held that the taxpayer was not able to argue the invalidity of...
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