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LITIGATION


Sarah Stenton and Lisa Vanderheide (Stewarts) examine HMRC’s approach to the charging of interest, and argue that it's time for a change.

Nick Skerrett and Heather Rowlands (Simmons & Simmons) discuss a landfill tax decision that is of wider interest as an example of HMRC rowing back on published guidance to minimise exposure to claims.
A recent Upper Tribunal decision provides a useful refresher of the steps that can be taken to reduce the possibility of HMRC successfully making a discovery, writes Helen Adams (BDO).
Catherine Robins and Sam Wardleworth (Pinsent Masons) review an interesting Upper Tribunal decision on the test for trading, 'golden contracts' and the availability  of enterprise zone allowances and legitimate expectation.
Jason Collins and Richard Dickman (Pinsent Masons) provide advice on how FTSE 100 companies can protect themselves from potential litigation.

This year has seen an increasing compliance burden for companies, an expansion of HMRC powers and a reminder of the important role of the courts, write Kate Ison and Jessica Hocking (Bryan Cave Leighton Paisner).

A decade of tax decisions examined by Michael Conlon QC (Temple Tax Chambers).
Adam Craggs and Constantine Christofi (RPC) review recent developments over the course of the past three months.  
The government intends to change the law retrospectively to make it clear that HMRC can use automated processes to issue notices to file returns and to issue penalties, report Catherine Robins and Steven Porter (Pinsent Masons).
The Court of Appeal's recent decision appears to set a high bar for establishing an unlawful breach of a taxpayer’s legitimate expectation, write Robert Waterson and Constantine Christofi (RPC).
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