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LITIGATION
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Stuart Walsh
Nuel Oji
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
Contentious tax: 2023 mid-year review
Clara Boyd
,
Lauren Redhead
,
Emily Burke
Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.
What happens at a tribunal hearing?
Anne Redston
Who sits where? What should you ask witnesses? When should you interrupt? Barrister Anne Redston provides a beginner’s guide to representing taxpayers at the tribunal.
SSE Generation: when is a tunnel a tunnel?
Will Scott
It all depends on the context... Will Scott (Norton Rose Fulbright) assesses the impact of a Supreme Court decision on the availability of capital allowances for increasingly novel technologies.
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
Cécile Perrault
Advisers may face potential claims long after providing the initial advice, explain Anastasia Nourescu and Cécile Perrault (Stewarts).
Judicial review: does the Court of Appeal’s decision in Murphy offer taxpayers a glimmer of hope?
Adam Craggs
Liam McKay
Judge on HMRC’s shoulder? A recent Court of Appeal ruling demonstrates that judicial review remains a vital and effective tool in defending taxpayers’ public law rights, write Adam Craggs and Liam McKay (RPC).
Mitchell: taxpayer confidentiality and a crisis of confidence?
Robert Waterson
Liam McKay
Robert Waterson and Liam McKay (RPC) suggest that the recent
Mitchel
l
case is indicative of a wider sense of apprehension in HMRC.
Deliberate behaviour: what you need to know
Sophie Rhind
Is it true that what you don’t know can’t hurt you? Sophie Rhind
(Macfarlanes) examines recent cases considering the level of knowledge
sufficient for a finding that a taxpayer’s behaviour is ‘deliberate’.
Getting closure: the FTT’s approach in Hitchins
Sophie Rhind
Victoria Braid
Sophie Rhind and Victoria Braid (Macfarlanes) examine when the tribunal
will exercise its power to direct HMRC to issue a closure notice in light of the
recent case of
Hitchins.
Please pay on your way out: UK exit charges and Gallaher
Ben Elliott
With the litigation on UK exit charges seemingly set to continue, Ben Elliott
(Pump Court Tax Chambers) examines the impact of a recent CJEU decision.
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48
EDITOR'S PICK
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
1 /7
What happens at a tribunal hearing?
Anne Redston
2 /7
Schedule 36: a stitch in time
Keith Gordon
3 /7
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
4 /7
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
5 /7
Tax Administration and Maintenance Day: report
6 /7
Pension planning after the Budget
Mike J Haynes
7 /7
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
What happens at a tribunal hearing?
Anne Redston
Schedule 36: a stitch in time
Keith Gordon
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
,
Cécile Perrault
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
,
Rhiannon Kinghall Were
Tax Administration and Maintenance Day: report
Pension planning after the Budget
Mike J Haynes
NEWS
Read all
Treasury Committee calls for systematic review of tax reliefs
NICs investment zone reliefs for employers
R&D claim requirements confirmed
New transfer pricing records requirements
HMRC issues clarifications on SBAs
CASES
Read all
M R Currell Ltd v HMRC
Sonder Europe Ltd v HMRC
TP v Administration de l’Enregistrement, des Domaines et de la TVA
Ebuyer (UK) Ltd v HMRC
Other cases that caught our eye: 28 July 2023
IN BRIEF
Read all
Self’s assessment: Inheritance tax
When does a payment constitute a distribution?
OECD inclusive framework publishes outcome statement on Pillar One and Pillar Two
Legislation day: practitioners' views
Challenging information notices
MOST READ
Read all