LITIGATION

Michael Cullers and Robert O’Hare (Squire Patton Boggs) examine a US Supreme Court decision that could have far-reaching ramifications for international entities carrying on business in the US.

Andrew Hubbard

A number of recent tribunal decisions have added to our understanding of how this important part of the tax system works, writes Andrew Hubbard (LexisNexis).

Four recent commentaries examine different aspects of the tax compliance landscape.

Jason Collins

The draft provisions contain a number of measures related to enforcement and HMRC powers. Jason Collins (Pinsent Masons) takes a look.

Chris Bates

Susie Brain

Chris Bates and Susie Brain (Norton Rose Fulbright) explore the debate in relation to some recent case law.

Nicholas Donnithorne

Matthew Harrison

Matthew Harrison and Nicholas Donnithorne (Babbé) examine two decisions which, in their view, reflect poorly on HMRC.

Kate Ison

Kate Ison (Bryan Cave Leighton Paisner) reviews the department’s strategy.

Kelly Stricklin-Coutinho

The role of commercial purpose in arm’s length rules is reconsidered by the CJEU, and appears more generous to taxpayers, writes Kelly Stricklin-Coutinho (39 Essex Chambers).

Helen Cox and Kassim Meghjee (Mishcon de Reya) consider the case’s progress through the courts and the practical impact of the Court of Appeal decision.

Richard Jeens

Charles Osborne

Richard Jeens and Charles Osborne (Slaughter and May) explain the practical points to consider both when drafting the tax indemnity and in the management of any subsequent claims.

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