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Upper Tribunal
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Upper Tribunal
UPPER-TRIBUNAL
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.
Certainty vs deterrence: the Supreme Court’s approach to anti-avoidance legislation in Fisher
Ben Elliott
The Supreme Court has effectively left it open to future courts to counteract artificial avoidance, writes Ben Elliott (Pump Court Tax Chambers).
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EDITOR'S PICK
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1 /7
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Tamar Ruiz
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Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
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Time is tight: CGT and the Autumn Budget
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What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
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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
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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
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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
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Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
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Corporate redomiciliation
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Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Apprenticeship Levy and Employment Allowance: new employer guidelines