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LITIGATION


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).
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.
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