APPEALS

New evidence after appeal: In Octagon Green Solutions v HMRC [2023] UKUT 268 (TCC) (6 November 2023), the company made a very late appeal against a landfill tax assessment but argued that it had a reasonable excuse, as HMRC had agreed not to take any...

Application to amend grounds of appeal refused.

Lauren Redhead Emily Burke Clara Boyd

Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.

Andrew Crozier

Edward Reed

Recent cases on information notices, penalties, and what is and is not a ‘mistake’ are reviewed by Edward Reed and Andrew Crozier (Macfarlanes).

Edward Reed

Tristan Honeyborne

The burden of proof as regards the taxpayer behaviour, late appeals and cautionary tales for IHT planning are among the topics featuring in this month’s review by Edward Reed and Tristan Honeyborne (Macfarlanes).

Anastasia Nourescu

HMRC appears to view many penalty appeals as a ‘second bite of the cherry’, even where the tribunal has not considered the earlier decision, writes Anastasia Nourescu (Stewarts).

Zoe Andrews

Mike Lane

The Upper Tribunal decisions in Altrad Services, BlackRock and Euromoney are examined by Mike Lane and Zoe Andrews (Slaughter and May).

Helen Adams

Helen Adams (BDO) considers the extent to which taxpayers may have a reasonable excuse if they are affected by the coronavirus pandemic and the UK’s lockdown.

A report by Tolley®Guidance on making appeals and applications to the First-tier Tribunal during the Covid-19 pandemic, with insight on appealing to the Upper Tribunal and judicial review.