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Upper Tribunal
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Upper Tribunal
UPPER-TRIBUNAL
Tax and the City review for January 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated
guidance on share exchanges.
Other cases that caught our eye: 13 September 2024
Publishing UT appeal decisions: Historically, decisions by the Upper Tribunal on applications for permission to appeal against decisions of the FTT have not been published. This practice has recently changed following a Practice Note issued by the...
A Outram and another v HMRC
UT overturns FTT finding of deliberate behaviour as error of law.
HMRC v The Taxpayer: balancing the public and private
Hugh Gunson
Hugh Gunson (Charles Russell Speechlys) examines when it is possible to obtain privacy and/or anonymity orders in tax tribunal proceedings in light of a recent Upper Tribunal decision.
HMRC v D Ridgway
Upper Tribunal rules against mixed use determination.
HMRC v The taxpayer
UT sets aside FTT’s direction that preliminary proceedings in the taxpayer’s appeal be heard in private.
View from the Tax Bar in 2023
Laura Poots
Laura Poots (Pump Court Tax Chambers) shares some tips for minimising last minute procedural issues and also reports some positive developments in diversity at the Bar.
Private client Christmas case round-up
Catrin Harrison
Dominic Lawrance
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) give a festive appraisal of the key case decisions in 2023 affecting private clients.
In conversation with... Rt Hon Lady Justice Falk
Anthony Inglese
Dame Sarah Falk talks to Anthony Inglese CB about her progression from life as a tax practitioner to becoming a senior member of the judiciary.
Capital allowances: a question of design?
Paul Farey
Paul Farey (AECOM) considers the impact of the Upper Tribunal’s ruling in
the
Gunfleet Sands
case.
Go to page
of
4
EDITOR'S PICK
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
1 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2 /7
2024: that was the year that was
Jemma Dick
3 /7
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
4 /7
The tractor tax
Stuart Maggs
5 /7
A third route to exit: tax consequences of continuation fund transactions
May Smith
,
Emily Szasz
6 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
7 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
The tractor tax
Stuart Maggs
A third route to exit: tax consequences of continuation fund transactions
May Smith
,
Emily Szasz
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
NEWS
Read all
HMRC manual changes: 17 January 2025
Tax investigations windfall for Chancellor
EU FASTER Directive published
CIOT highlights risks of proposed NICs changes
Making Tax Digital: updated guidance and new awareness events
CASES
Read all
HMRC v Yorkshire Agricultural Society
The Mersey Docks and Harbour Company Ltd v HMRC
Bridgecom International Ltd v HMRC
Other cases that caught our eye: 17 January 2025
JTC Employer Solutions Trustee Ltd and others v W Garnett and others
IN BRIEF
Read all
Balancing growth and taxes: the corporate tax roadmap
The increased interest rate on late payments
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
MOST READ
Read all
JTC Employer Solutions Trustee Ltd and others v W Garnett and others
M R Currell Ltd v HMRC
Chemidex Generics Ltd v HMRC
NHS Mid & South Essex ICB and others v HMRC
Tax exemption for LGBT Financial Recognition Scheme payments