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Appeals
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APPEALS
The last word on tax appeals
Malcolm Gammie CBE KC
The Supreme Court stands at the head of the UK’s judicial appeals system.
Malcolm Gammie CBE KC (One Essex Court) examines when permission
to appeal to the Supreme Court is likely to be granted, and considers how
taxpayers and HMRC are faring in securing permission.
HMRC v S&L Barnes Ltd
Upper Tribunal allows HMRC’s IR35 appeal.
HMRC v Labeikis and others
High Court strikes out Part 8 loan charge claims.
Case management before the tribunal
Dan Williams
Adam Craggs
Adam Craggs and Dan Williams (RPC) consider the various stages
involved in an appeal to the First-tier Tribunal and focus on the FTT’s case
management powers throughout the process.
Jelly Vine Productions Ltd v HMRC
Taxpayer’s attempt to avoid full IR35 hearing on previously untested procedural grounds is rejected.
No joy for JTIAC: an extension of the unallowable purpose principle
Constantine Christofi
The last in a trilogy of recent Court of Appeal cases on ‘unallowable purpose’ has seemingly extended its ambit yet further, writes Constantine Christofi (EY).
T Watts v HMRC
UT dismisses gilt strips scheme appeal.
Back to basics: Closure notices and the appeals process
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) provide a refresher guide.
L v HMRC
A successful anonymity application.
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Dominic Robertson
Deepesh Upadhyay
Deepesh Upadhyay (Eversheds Sutherland) and Dominic Robertson
(Slaughter and May) examine one of the most important withholding tax
cases in years.
Go to page
of
4
EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
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R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
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Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
Apprenticeship Levy and Employment Allowance: new employer guidelines
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC