Your quarterly review of developments in the contentious tax world, by Jason Collins and Lauren Redhead (DLA Piper).
Preliminary issues having a big impact
We observed in our end of year review (‘Tax disputes in 2021: beware the clever procedural skirmish’ Tax Journal 10 December 2021) the current trend towards seeking to try some issues in a case on a ‘preliminary’ basis as a way to end disputes without all the points needing to be decided. So far in 2022 decisions in two noteworthy cases that started their lives with preliminary issue hearings have already been released each having significant ramifications for the parties.
HSBC
In HSBC Electronic Data Processing (Guangdong) Ltd and others [2022] UKUT 41 (TCC) the Upper Tribunal issued its judgment in respect of four preliminary issues in an appeal.
Back in 2020 the First-tier Tribunal (FTT) had directed...
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Your quarterly review of developments in the contentious tax world, by Jason Collins and Lauren Redhead (DLA Piper).
Preliminary issues having a big impact
We observed in our end of year review (‘Tax disputes in 2021: beware the clever procedural skirmish’ Tax Journal 10 December 2021) the current trend towards seeking to try some issues in a case on a ‘preliminary’ basis as a way to end disputes without all the points needing to be decided. So far in 2022 decisions in two noteworthy cases that started their lives with preliminary issue hearings have already been released each having significant ramifications for the parties.
HSBC
In HSBC Electronic Data Processing (Guangdong) Ltd and others [2022] UKUT 41 (TCC) the Upper Tribunal issued its judgment in respect of four preliminary issues in an appeal.
Back in 2020 the First-tier Tribunal (FTT) had directed...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
