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LITIGATION


Matthew Harrison (Withers) examines the impact of a recent Supreme Court decision.
Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine what is effectively the pilot episode for an upcoming courtroom drama.
Jackie Wheaton (BDO) examines the case law in determining when a company is resident in the UK for tax purposes.
Dominic Stuttaford and Sofia Casselbrant-Multala (Norton Rose Fulbright) review the NICs treatment of bonus payments by LLP to former employees who subsequently become members.
The General Court’s decision shows the difficulties the European Commission faces in proving selective tax advantages that may constitute unlawful state aid, write George Peretz QC and Tarlochan Lall (Monckton Chambers).
The scope of negative earnings is almost certainly wider than has generally been appreciated, writes Nigel Doran (Macfarlanes).
A recent Court of Appeal decision reaffirms HMRC’s right to conduct enquiries on an ‘informal’ premise even where there is no statutory basis, write Kate Ison and Jessica Hocking (Bryan Cave Leighton Paisner).
The treatment of call options had been considered settled for over 40 years, but HMRC now wishes to reimagine it. Chris Nyland (Gowling WLG) analyses the merits of HMRC’s logic and its actions.
Contrary to HMRC’s guidance and CEST tool, mutuality of obligation is pivotal to determining employment status in surprising ways. Derek Francis (Terra Firma Chambers) examines cases showing how.
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