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LITIGATION


Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.
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).
There has been a steady rise in disputes concerning IHT and SDLT, report Adam Craggs and Harry Smith (RPC).
Jake Landman and Abigail McGregor (Pinsent Masons) explain how estoppel has recently been used in tax cases by HMRC and also by taxpayers.
The Supreme Court has delivered its judgment in Centrica Overseas HoldingsKyle O’Sullivan (BCLP) reviews the case and its implications.
In GE Financial Investments, the Upper Tribunal favoured the functional interpretation while the Court of Appeal favoured the territorial, writes Kyle Rainsford (Addleshaw Goddard).
The principle of open justice is the overarching theme in this review by Adam Craggs and Harry Smith (RPC).
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).
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).
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and its implications going forward.
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