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APPEALS


Andrew Goldstone and Katie Doyle (Mishcon de Reya) provide your monthly update on the latest tax developments affecting private clients.
 
Taxpayers should question their legal advisers carefully about bringing future challenges to the accelerated payment notices regime if they are not to throw good money after bad. Patrick Cannon (15 Old Square) reviews the four reported judicial review challenges to APNs of note.
 
Lord Carnwath’s ‘brief comment’ in Pendragon addresses the appellate jurisdiction of the Upper Tribunal and Court of Appeal in tax appeals. John Brinsmead-Stockham (Tax Chambers, 11 New Square) analyses its impact.
 

Recent data suggests that if you think HMRC is wrong, there is a significant chance that it may be, says John Barnett (Burges Salmon)

Charlotte Brown (Quorum Tax Chambers) considers the FTT’s recent approach to resolving VAT disputes where HMRC refuses to issue an appealable decision

Taxpayers increasingly need to rely on statements made by HMRC which do not have the force of law, such as HMRC clearances given to a taxpayer or HMRC guidance. In this back-to-basics guide, Christopher Harrison and David Stainer (Allen & Overy) provide an overview of the principles which govern a taxpayer’s ability to rely on written statements by HMRC, particularly on legitimate expectation.

Angela Savin reports on the proposed amendments to the grounds of appeal for follower notices penalties

Michael Ripley says there is a ‘glaring lacuna’ for indirect tax appeals

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