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LITIGATION
Contentious tax in 2020
Rupert Shiers
Adam Parry
Rupert Shiers and Adam Parry (Hogan Lovells) report on some significant
cases and indications of a tougher approach by HMRC.
Contentious tax: quarterly review
Constantine Christofi
Adam Craggs
Recent trends in the contentious tax world, by Adam Craggs and
Constantine Christofi (RPC).
Total: just and reasonable profit apportionment
Jake Landman
Jake Landman (Pinsent Masons) examines the Court of Appeal decision and its wider implications.
Litigation privilege and structuring advice
Dominic Stuttaford
Tax structuring advice received and implemented, even where there is a
perceived risk of challenge, will not benefit from litigation privilege, writes
Dominic Stuttaford (Norton Rose Fulbright).
BlackRock and unallowable purpose
Heather Self
A recent tribunal decision on whether the taxpayer had an unallowable
purpose is likely to be of wide application, as Heather Self (Blick Rothenberg)
explains. But was it correctly decided?
Civil or criminal proceedings for serious fraud?
David Sleight
David Sleight (Kingsley Napley) examines a recent Upper Tribunal decision which is important for both tax and criminal litigators alike.
Judicial review of exchange of information requests
Gary Barnett
Monique van Herksen
Monique van Herksen and Gary Barnett (Simmons & Simmons) examine
a recent decision of the CJEU that presents a setback for taxpayers in this
developing area of law.
Boulting: jurisdiction and the rule of law
Constantine Christofi
Robert Waterson
Adam Craggs
Adam Craggs, Robert Waterson and Constantine Christofi (RPC) examine the High Court decision that refused permission to bring a judicial review claim against HMRC.
AXA v Genworth: gross misunderstandings?
Helen Coward
Helen Coward (Charles Russell Speechlys) reviews a recent High Court case
on the meaning of a gross-up clause in a share purchase agreement.
Charman: old ERS law, new insights
Nigel Doran
Philip Swinburn
Nigel Doran and Philip Swinburn (Macfarlanes) examine the Upper Tribunal decision on the employment-related securities provisions of ITEPA 2003 Part 7.
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50
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way