LITIGATION

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. 

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.

Some good news and some bad news.

Barrister Patrick Cannon (15 Old Square) provides first hand insight on when and how to use mediation to resolve tax disputes.

Adam Craggs and Constantine Christofi (RPC) consider the recent spate of IR35 cases that have been considered by the First-tier Tribunal, HMRC's increasing use of 'jeopardy amendments' and the increasing number of judicial review challenges being brought against HMRC.  

Sabina Margulies (Lexis®PSL Tax) reviews lessons from the Court of Appeal judgment.

Despite little change in the primary law, HMRC's practice over its information powers is changing due to continued pressure to increase tax yield and demands for data from its international counterparts, as experts at Deloitte explain.