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Judicial review
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Judicial review
JUDICIAL-REVIEW
DPT notices and APAs: the implications of Refinitiv
Paula Ruffell
Astrid Vroom
Paula Ruffell and Astrid Vroom (
EY)
consider the implications of
Refinitiv
to transfer pricing methodologies adopted in multiple years and what this means for APAs and DPT assessments more generally.
Other cases that caught our eye: 19 January 2024
The meaning of ‘residence’ for LBTT purposes: A Blue v Revenue Scotland [2023] FTSTC 4 (21 December 2023) is a case on the additional dwelling supplement rules for Scottish land and buildings transaction tax, particularly the rules relating to...
Private client review for September 2023
Kathryn Hart
Edward Reed
Domicile disputes, exceptional circumstances, judicial review... Edward Reed and Kathryn Hart (Macfarlanes) review recent developments in the private client world.
R (oao London Fluid System Technologies Ltd and others) v HMRC
Judicial review.
Holding HMRC to a statement
Jake Landman
Abigail McGregor
Jake Landman and Abigail McGregor (Pinsent Masons) review two recent cases exploring the circumstances where a taxpayer can, and can’t, rely on a statement made by HMRC in order to establish a legitimate expectation.
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).
Back to basics: Accelerated payment notices and follower notices
Sam Wardleworth
Steven Porter
Steven Porter and Sam Wardleworth (Pinsent Masons) provide a refresher guide to these ‘game changing’ regimes.
KSM Henryk Zeman: FTT and legitimate expectation revisited
Clara Boyd
Catherine Robins
The
KSM
decision offers some glimmers of hope to those who think the FTT
should have jurisdiction to consider incidental public law issues, write
Clara Boyd and Catherine Robins (Pinsent Masons).
Judicial reviews against HMRC: judge over your shoulder?
Oliver Marre
Barrister Oliver Marre (5 Stone Buildings) reflects on the use of judicial
review as a key safeguard on HMRC’s powers.
Judicial review of exchange of information requests
Gary Barnett
Monique van Herksen
Monique van Herksen and Gary Barnett (Simmons & Simmons) examine
a recent decision of the CJEU that presents a setback for taxpayers in this
developing area of law.
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of
3
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
Read all
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
Read all
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