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LITIGATION
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Nuel Oji
Stuart Walsh
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
Contentious tax: 2023 mid-year review
Lauren Redhead
Emily Burke
Clara Boyd
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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50
EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
Tax Journal authors for November 2024
HMRC manual changes: 6 December 2024
Exchequer Secretary committed to MTD timetable following ‘robust’ conversations with HMRC
MTD: catching up with digital records
No new side hustle tax, HMRC confirm
CASES
Read all
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
L v HMRC
Other cases that caught our eye: 6 December 2024
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
Stage One Creative Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others