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LITIGATION


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).
It is difficult to see how the test for legitimate expectation set by the Court of Appeal could ever be met.
Normative underpinnings and the public interest in tax collection
Giles Salmond and Matthew Cummings (Eversheds Sutherland) examine the Supreme Court decision in Frank A Smart Ltd & Son.
The loan charge has driven a coach and horses through the statutory safeguards, writes barrister Keith Gordon (Temple Tax Chambers). 
Britain’s future prosperity depends on a revival in its productivity growth, writes Sam Mitha CBE. How can tax policy help?

Despite the review being an important event, it appears to be very much business as usual at HMRC.

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