LITIGATION

Kate Ison

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).

Chris Nyland

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.

Derek Francis

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.

Emily Clark

Sometimes you can be too relaxed.

Matthew Harrison

Matthew Harrison (Withers) examines the Upper Tribunal decision concerning the registered pension scheme regime.

David Whiscombe

The unsatisfactory truth.

Dominic Stuttaford

Susie Brain

Dominic Stuttaford and Susie Brain (Norton Rose Fulbright) examine the Court of Appeal decision.

Peter Nias

The president of the tax chamber of the First-tier Tribunal has issued a practice statement on the use of alternative dispute resolution in tax disputes. Peter Nias (Pump Court Tax Chambers), who was instrumental in its issue, considers its significance and what it can mean for tax dispute management.