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APPEALS
Penalty appeals: shedding light on abuse of process
Anastasia Nourescu
HMRC appears to view many penalty appeals as a ‘second bite of the cherry’, even where the tribunal has not considered the earlier decision, writes Anastasia Nourescu (Stewarts).
Tax and the City review for September 2022
Zoe Andrews
Mike Lane
The Upper Tribunal decisions in
Altrad Services
,
BlackRock
and
Euromoney
are examined by Mike Lane and Zoe Andrews (Slaughter and May).
Covid-19 and reasonable excuse
Helen Adams
Helen Adams (BDO) considers the extent to which taxpayers may have a reasonable excuse if they are affected by the coronavirus pandemic and the UK’s lockdown.
Tax appeals during the Covid-19 pandemic
A report by Tolley®Guidance on making appeals and applications to the First-tier Tribunal during the Covid-19 pandemic, with insight on appealing to the Upper Tribunal and judicial review.
How to handle tax appeals
Constantine Christofi
Adam Craggs
A 20 questions guide, by Adam Craggs and Constantine Christofi
(RPC).
Ames: a cautionary tale
Andrew Goldstone
Andrew Goldstone (Mishcon de Reya) believes that a recent case raises concerns over HMRC’s approach to litigation and illustrates the need for change in the EIS legislation.
Addo: disclosure in tax appeals
Constantine Christofi
Adam Craggs
Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision.
Private client briefing for September 2018
Andrew Goldstone
Katie Doyle
Andrew Goldstone and Katie Doyle (Mishcon de Reya) provide your monthly update on the latest tax developments affecting private clients.
The failed JR challenges to APNs: lessons to be learned?
Patrick Cannon
Taxpayers should question their legal advisers carefully about bringing future challenges to the accelerated payment notices regime if they are not to throw good money after bad. Patrick Cannon (15 Old Square) reviews the four reported judicial review challenges to APNs of note.
Tax appeals: what is the ‘point of law’?
John Brinsmead-Stockham
Lord Carnwath’s ‘brief comment’ in
Pendragon
addresses the appellate jurisdiction of the Upper Tribunal and Court of Appeal in tax appeals. John Brinsmead-Stockham (Tax Chambers, 11 New Square) analyses its impact.
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5
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way