LITIGATION

David Haworth and David Haughey (Freshfields) examine the implications of the Court of Appeal’s decision for businesses which are potentially within the scope of the UK’s salaried member rules.

Gerald Montagu

Elmira Jazottes

Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.

Sophie Rhind

Victoria Braid

Mainpay should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).

Harry Smith

Adam Craggs

There has been a steady rise in disputes concerning IHT and SDLT, report Adam Craggs and Harry Smith (RPC).

Jake Landman

Abigail McGregor

Jake Landman and Abigail McGregor (Pinsent Masons) explain how estoppel has recently been used in tax cases by HMRC and also by taxpayers.

Kyle O'Sullivan

The Supreme Court has delivered its judgment in Centrica Overseas Holdings. Kyle O’Sullivan (BCLP) reviews the case and its implications.

Kyle Rainsford

In GE Financial Investments, the Upper Tribunal favoured the functional interpretation while the Court of Appeal favoured the territorial, writes Kyle Rainsford (Addleshaw Goddard).

Harry Smith

Adam Craggs

The principle of open justice is the overarching theme in this review by Adam Craggs and Harry Smith (RPC).

Thomas Chacko

The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).

Michael Ridsdale

Gemma Williams

Exceptions to the doctrine of precedent do exist but, as a recent case illustrates, they will be rarely applied in practice, write Michael Ridsdale and Gemma Williams (Wedlake Bell).

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