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Staleness
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Staleness
STALENESS
Tax and the City review for March 2023
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.
Tax procedure’s dead parrot: staleness and stare decisis
Craig Kirkham-Wilson
Craig Kirkham-Wilson (Simmons & Simmons) reviews a recent decision of the Upper Tribunal on staleness and Supreme Court precedent.
Private client review for June 2022
Edward Reed
Andrew Crozier
Decisions on the validity of discovery assessments and information notices are among the recent developments reviewed by Edward Reed and Andrew Crozier (Macfarlanes).
Contentious tax quarterly
Constantine Christofi
Adam Craggs
Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
Discovery following Tooth: what should advisers do now?
Helen Adams
Helen Adams (BDO) considers the ways the Supreme Court decision will change advisers’ approach to discovery appeals.
Tooth, staleness and protective assessments
Sophie Lloyd
Rob Smith
What does the decision mean for protective assessments?
Discovery assessments: the Supreme Court’s decision in Tooth
Clara Boyd
Ian Robotham
Clara Boyd and Ian Robotham (Pinsent Masons) examine the unanimous decision that clarifies the law in relation to discovery assessments.
Mehrban: staleness takes the biscuit
HMRC can’t wait forever to make a discovery assessment.
Another day, another BBC IR35 case: with a sting in the tail
David Whiscombe
In yet another IR35 case, a tribunal considers the procedural validity of the determinations under which HMRC sought to collect the tax.
'Staleness' and discovery: where are we now following the judgment in Tooth?
Natalie Martin
The judgment in
Tooth
increases the weight of authority behind the issue of 'staleness', but that concept is not yet settled.
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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
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James Burton
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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
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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
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Treasury Committee calls for systematic review of tax reliefs
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M R Currell Ltd v HMRC
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Test4- GE Financial, treaty residence, and the meaning of ‘business
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