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LITIGATION
Tax and the City review for March 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in
Lloyds Asset Leasing
and
Royal Bank of Canada
, as well
as HMRC’s plans to update guidance on the salaried member rules.
RBC: from the island of literal interpretation to the continental shelf
Kyle Rainsford
Victoria Hine
RBC
reopens some old
Ramsay
uncertainties. Victoria Hine and
Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.
Findings of fact are stubborn things: A Taxpayer v HMRC
Catrin Harrison
Dominic Lawrance
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys)
consider the implications of the Court of Appeal judgment.
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
David Haughey
David Haworth and David Haughey (Freshfields) examine the implications of the Court of Appeal’s decision for businesses which are potentially within the scope of the UK’s salaried member rules.
Tax, memory and the written record: revisiting Gestmin
Gerald Montagu
Elmira Jazottes
Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.
Rebel without a causal link: HMRC’s position on proving carelessness
Sophie Rhind
Victoria Braid
Mainpay
should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
Contentious tax quarterly: Autumn 2024
Harry Smith
Adam Craggs
There has been a steady rise in disputes concerning IHT and SDLT, report
Adam Craggs and Harry Smith (RPC).
Estoppel in a tax context
Jake Landman
Abigail McGregor
Jake Landman and Abigail McGregor (Pinsent Masons) explain how
estoppel has recently been used in tax cases by HMRC and also by taxpayers.
A capital blow for deducting management expenses
Kyle O'Sullivan
The Supreme Court has delivered its judgment in
Centrica Overseas Holdings
.
Kyle O’Sullivan (BCLP) reviews the case and its implications.
The Court of Appeal favours form over function in GE Financial
Kyle Rainsford
In
GE Financial Investments
, the Upper Tribunal favoured the functional
interpretation while the Court of Appeal favoured the territorial, writes
Kyle Rainsford (Addleshaw Goddard).
Go to page
of
50
EDITOR'S PICK
Sample India’s 2025 GST Amendments
Test Samarth
1 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
2 /7
Understanding the FIG regime
Jo Bateson
3 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
4 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
5 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
6 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
7 /7
Sample India’s 2025 GST Amendments
Test Samarth
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
NEWS
Read all
Sample India’s 2025 GST Amendments
Test-Chancellor outlines financial services strategy
Test16/09/2025-Chancellor outlines financial services strategy
Test16/09/2025-Chancellor outlines financial services strategyAA
HMRC manual changes: 18 July 2025
CASES
Read all
Sample India’s 2025 GST Amendments
Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
IN BRIEF
Read all
HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
MOST READ
Read all
‘Legislation Day’ date announced
G Haworth and others v HMRC
One Big Beautiful Bill Act enacted
Abbotsford Property Group Ltd and another v Revenue Scotland
One minute with... Charlie Friend