TAX POLICY ADMINISTRATION

Recent cases suggest a worrying trend towards HMRC adopting a more combative approach to judicial review proceedings, write Robert Waterson and Rebekka Sandwell (Eversheds Sutherland).

Sam Wardleworth

Steven Porter

The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).

Steve Wade

The proposed reforms to Overseas Workday Relief could have greatly simplified administration for taxpayers, agents and HMRC. Steve Wade (EY) examines what’s actually been proposed.

Tanja Velling

Tanja Velling (Slaughter and May) reviews a significant FTT decision in which the taxpayers were denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule.

Kunal Nathwani

There are questions over the use of AI by HMRC under the existing legislation and the adequacy of current taxpayer safeguards, writes Kunal Nathwani (Kirkland & Ellis).

Gerald Montagu

Elmira Jazottes

Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.

Siobhan Gillespie

George Gillham

George Gillham and Siobhan Gillespie (Fieldfisher) assess HMRC’s track record.

Adam Craggs

Liam McKay

We are likely to see a consistent increase in the use of mediation in tax disputes. Adam Craggs and Liam McKay (RPC) explain when and how it is in the taxpayer’s interests.