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JUDICIAL-REVIEW


Principled positions often adopted by HMRC can have the practical effect of avoiding or otherwise delaying judicial scrutiny of their decision-making process, write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).
A recent High Court decision provides valuable guidance for taxpayers seeking to challenge enforcement action taken by HMRC’s Debt Management team, write Michelle Sloane and Daniel Williams (RPC).
Adam Craggs and Liam McKay (RPC) review lessons from several important procedural decisions and a successful challenge to HMRC’s approach to subject access requests.
In an adversarial system, when can the tribunal take the initiative and reach decisions on arguments not made by counsel? Bridget Winters and Calum Young (Taylor Wessing) investigate.
Disguised remuneration schemes, end users and judicial review: It is now accepted that most, if not all, disguised remuneration schemes involving the making of loans to employees via an employee benefit trust do not work and that the arrangements...
Upper Tribunal decides that HMRC lawfully refused late claim under SP 5/01
Adam Craggs and Liam McKay (RPC) set out the general principles and the practical aspects of advancing a judicial review claim.
What is a bar?
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated guidance on share exchanges.
This year has seen decisions on anonymity in tax appeals, cross-examination in judicial review, and failing to comply with tribunal directions. Adam Craggs and Liam McKay (RPC) investigate.
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