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Partial closure notices
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Partial closure notices
PARTIAL-CLOSURE-NOTICES
The other Greek case: Embiricos reaches the Court of Appeal
Dominic Lawrance
Catrin Harrison
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) examine the Court of Appeal’s decision on partial closure notices in respect of domicile cases.
Contentious tax quarterly
Constantine Christofi
Adam Craggs
HMRC seems more amenable to alternative dispute resolution, whilst also pushing for greater formality in tax appeals, report Adam Craggs and Constantine Christofi (RPC).
Embiricos and the future of partial closure notices
Dominic Lawrance
Hugh Gunson
Catrin Harrison
Catrin Harrison, Dominic Lawrance and Hugh Gunson (Charles Russell Speechlys)
examine an Upper Tribunal decision that is disappointing for taxpayers and
removes a strategic weapon for anyone faced with a domicile enquiry.
Closing HMRC enquiries
Craig Thomson
We now have two recent opposing tribunal judgments on how the partial closure notice rules operate, writes Craig Thomson (Grant Thornton).
EDITOR'S PICK
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
1 /7
OECD pillar talk: Pillar Two looming; Pillar One a step closer
Brin Rajathurai
,
James Burton
,
Mitchell Fraser
2 /7
NICs investment zone reliefs for employers
3 /7
New transfer pricing records requirements
4 /7
UK adopts Pillar Two accounting changes
5 /7
M R Currell Ltd v HMRC
6 /7
Legislation day: draft Finance Bill 2024
7 /7
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
OECD pillar talk: Pillar Two looming; Pillar One a step closer
Brin Rajathurai
,
James Burton
NICs investment zone reliefs for employers
New transfer pricing records requirements
UK adopts Pillar Two accounting changes
M R Currell Ltd v HMRC
Legislation day: draft Finance Bill 2024
NEWS
Read all
Test4- GE Financial, treaty residence, and the meaning of ‘business
Test3- GE Financial, treaty residence, and the meaning of ‘business
Test- GE Financial, treaty residence, and the meaning of ‘business
Test2- GE Financial, treaty residence, and the meaning of ‘business
Treasury Committee calls for systematic review of tax reliefs
CASES
Read all
Test4- GE Financial, treaty residence, and the meaning of ‘business
Test3- GE Financial, treaty residence, and the meaning of ‘business
Test- GE Financial, treaty residence, and the meaning of ‘business
Test2- GE Financial, treaty residence, and the meaning of ‘business
M R Currell Ltd v HMRC
IN BRIEF
Read all
Test4- GE Financial, treaty residence, and the meaning of ‘business
Test3- GE Financial, treaty residence, and the meaning of ‘business
Test- GE Financial, treaty residence, and the meaning of ‘business
Test2- GE Financial, treaty residence, and the meaning of ‘business
Self’s assessment: Inheritance tax
MOST READ
Read all