LITIGATION

Peter Vaines

It is difficult to see how the test for legitimate expectation set by the Court of Appeal could ever be met.

Stephen Daly

Normative underpinnings and the public interest in tax collection

Giles Salmond

Matt Cummings

Giles Salmond and Matthew Cummings (Eversheds Sutherland) examine the Supreme Court decision in Frank A Smart Ltd & Son.

Keith Gordon

The loan charge has driven a coach and horses through the statutory safeguards, writes barrister Keith Gordon (Temple Tax Chambers).

Sam Mitha CBE

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.

The UK has published draft regulations adopting an EU directive that promises faster resolution of double taxation disputes between member states.

Adam Craggs

Michelle Sloane

In this quarterly review, Adam Craggs and Michelle Sloane (RPC) consider HMRC’s increasing propensity to seek the production of documents from accountants and other professional advisers, HMRC’s new policy of challenging taxpayers’ loan relationships, and the increase in the number of domicile enquiries launched by HMRC.

David Pett

David Pett (Temple Tax Chambers) argues that outstanding loan charges should be pursued both as a matter of law and social policy.

Dominic Stuttaford

Sofia Casselbrant

Sofia Casselbrant-Multala and Dominic Stuttaford (Norton Rose Fulbright) examine the Court of Appeal decision in Rossendale that demonstrates the potential general application of the Ramsay approach, but clearly shows its limits as a means of countering avoidance.

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