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LITIGATION


This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Lloyds Asset Leasing and Royal Bank of Canada, as well as HMRC’s plans to update guidance on the salaried member rules.
RBC reopens some old Ramsay uncertainties. Victoria Hine and Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) consider the implications of the Court of Appeal judgment.
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 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).
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