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APPEALS


How close is close enough? Orsted and the limits of ‘on the provision of plant’ premium
Card image Paul Farey
Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.
29 April 2026
Penalty suspension premium
Card image Jake Landman
Card image Abigail McGregor
Jake Landman and Abigail McGregor (Pinsent Masons) revisit the discretionary regime allowing HMRC to suspend penalties for careless inaccuracies, in light of recent Upper Tribunal guidance.
25 March 2026
Back to square one: late appeals after Medpro premium
Card image Adam Craggs
Card image Liam McKay
The Court of Appeal restores a strict approach to late appeals, leaving taxpayers facing the familiar Martland hurdle once again, write Adam Craggs and Liam McKay (RPC).
18 February 2026
Estoppel and abuse of process in VAT starpremium
Card image Claire Logan
Claire Logan (Grant Thornton) explains why estoppel and abuse of process are increasingly relevant in VAT disputes and how they can materially affect how cases are argued and resolved.
24 June 2026
The last word on tax appeals premium
Card image Malcolm Gammie CBE KC
The Supreme Court stands at the head of the UK’s judicial appeals system. Malcolm Gammie CBE KC (One Essex Court) examines when permission to appeal to the Supreme Court is likely to be granted, and considers how taxpayers and HMRC are faring in securing permission.
11 September 2024
Misunderstanding purpose in Osmond and Allen starpremium
Card image Thomas Chacko
The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).
3 July 2024
Changes to applying for permission to appeal premium
Card image Sophie Rhind
Sophie Rhind (Macfarlanes) reports on the game changing amendment to rule 24 of the Upper Tribunal rules.
22 June 2022
Contentious tax quarterly premium
Card image Constantine Christofi
Card image Robert Waterson
Recent trends in the contentious tax world, by Robert Waterson and Constantine Christofi (RPC).
22 September 2021
Indirect effects: who can appeal a judgment?
Card image Victor Cramer
What rights do those indirectly affected by tax disputes have if they disagree with the outcome? 
8 July 2021
Contentious tax: quarterly review premium
Card image Constantine Christofi
Card image Adam Craggs
Your quarterly review of developments in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
5 June 2020
EDITOR'S PICKstar
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Abbey Group Ltd v HMRC
29 October 2026
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