LITIGATION

CGT and uncompleted contracts.

Rory Mullan (Old Square Tax Chambers) examines two cases that demonstrate the importance of establishing the fundamental requirements of the TOAA code before a charge can be imposed.

Charlotte Anderson

Emily Szasz

Emily Szasz and Charlotte Anderson (Freshfields Bruckhaus Deringer) examine the FTT decision on the interaction between domestic appeals and MAPs which are provided for in double tax treaties.

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.

Liz Wilson

It is difficult to discern any guiding principles on the application of the IR35 rules from these two latest cases, writes Liz Wilson (Squire Patton Boggs).

Martin Voelker

Paul Miller

Paul Miller and Martin Voelker (Ashurst) examine a recent tribunal decision on the economic reality of making supplies in the context of tripartite arrangements and what constitutes third party consideration.

Paul Farmer

Peter Stewart

Peter Stewart and Paul Farmer (Joseph Hage Aaronson) examine the decision that so-called agility hire purchase contracts are a supply of services and consider its practical implications.

Lee Squires

Fiona Bantock

Lee Squires and Fiona Bantock (Hogan Lovells) report the latest VAT developments that matter.

Heather Self

Heather Self (Pinsent Masons) examines the FTT decision where a UK corporate taxpayer succeeded in an argument about loan relationships or financial instruments against HMRC.

Simon Whitehead

Joseph Irwin

Simon Whitehead and Joseph Irwin (Joseph Hage Aaronson) review the Court of Appeal’s recent judgment in the franked investment income group litigation.

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