HMRC, Disclosures & Compliance Risk
Worldwide disclosures, historic risk, reporting failures, penalties and practical response strategies.
“Stay ahead of the Tax curve!”
The appellant, Peter Marano, contested penalties imposed by HM Revenue and Customs (HMRC) for the late submission of his self-assessment tax return for the tax year 2012/2013. The case revolved around whether HMRC needed to prove that an "officer of the Board" was involved in issuing a notice requiring the submission of a tax return.
March 23, 2026
HMRC to increase late payment interest to 8.5% from April 2025
As first announced in the autumn budget 2024, HMRC will increase the interest rate charged on late payment of most taxes and duties from 7% to 8.5%, starting 6 April 2025.
This change reflects a wider government initiati...
March 18, 2026
HMRC’s renewed focus on interest deductions
Over the past several months, HMRC has been writing to a number of companies — typically those with open enquiries into the deductibility of interest on acquisition or group financing arrangements — referencing the so-called “unallowable purpose rule” under sections 441–442 of the Corporation Tax Act 2009.
March 18, 2026
The “insurance” letter that ruins a Saturday
Alex is 46, UK-resident, busy, and financially organised (or so he thinks). One Saturday morning he opens a thick envelope from an insurer. The headline is bland:
March 18, 2026
Is that HMRC Letter genuine? know how to check
In today’s digital age, more businesses and individuals are receiving communications claiming to be from HMRC.
March 18, 2026
Fisher v HMRC: A big win for UK Taxpayers
Big news in the world of tax! The Supreme Court has just ruled in Fisher v HMRC, a case that could impact UK businesses with overseas interests. But while the decision is a win for taxpayers, it's not the time to get too...
March 18, 2026
“Correct and complete” What HMRC’s new focus really means for you
He’s a successful founder: UK company, overseas investments, a trust, a carried interest structure, a couple of properties in Europe. He has a Big 4 firm on speed dial and a family office that keeps his spreadsheets immaculate.
March 18, 2026
HMRC Nudge Letter: the brown envelope on a rainy Tuesday
A simple guide to HMRC’s “nudge letter” when you have assets in Italy and Spain
“I thought it was a parking fine.”
March 18, 2026
When VAT isn’t what it seems
When VAT isn't what it seems: reverse charge, registration traps, and why you might already be liable
March 18, 2026
The “first-time buyer” who wasn’t (SDLT)
I’m going to tell you a story that looks “obvious” in real life… and then becomes very non-obvious once you apply the statute.
Let’s call them Marco and Giulia. Long-term renters in London. Offer accepted. Mortgage lined up. They’ve budgeted for fees and assume they qualify for SDLT First-Time Buyers’ Relief because: “We’ve never owned a home in the UK.”
March 18, 2026
READY TO TAKE THE NEXT STEP?
Clearer Perspectives on Complex Tax
Technical commentary is only the starting point. Whether navigating complex HMRC enquiries or structuring international investments, Angelo Chirulli provides the high-level technical depth and strategic clarity required to deliver robust tax solutions.