LITIGATION

Stuart Walsh

Jason Collins and Stuart Walsh (Pinsent Masons) review a recent tribunal case which highlights the practical difficulties of asserting legal privilege where the taxpayer has to explain their motivations behind a transaction.

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) review a recent tribunal decision which considers disclosure and the practical effect of Sanderson.

David Whiscombe

‘One is tempted to say “taxpayers lose hopeless cases” and leave it at that,’ writes David Whiscombe (BKL) in his review of the decision in Christianuyi.

Clare Reeve Curatola

Kate Ison

The decision in Bilta has clarified the scope of privilege in internal investigations undertaken in the context of HMRC enquiries, write Kate Ison and Clare Reeve (Berwin Leighton Paisner).

Martin Shah

Gary Barnett

Martin Shah and Gary Barnett (Simmons & Simmons) review the latest VAT developments that matter.

James Hamon

Mark Brailsford

To QCB or not to QCB? Mark Brailsford and James Hamon (Berwin Leighton Paisner) review the judgment in Trigg on whether bonds were QCBs, and consider the wider impact on statutory interpretation.

Heather Self

Heather Self (Blick Rothenberg) assesses the impact of the recent Court of Appeal judgment in Lomas on whether interest is ‘short’ or ‘yearly’.

Richard Jeens

Richard Jeens (Slaughter and May) reviews a busy year for tax disputes, both in terms of the scale and number of DPT and transfer pricing enquiries and a number of significant court decisions.

Nick Skerrett

Nick Skerrett (Simmons & Simmons) examines the background, issues and impact of the much awaited decision on ‘adequate indemnity’.

Helen Adams

Youcef Toumi

Helen Adams and Youcef Toumi (BDO) examine the current state of the legislation and case law on reasonable excuse, including how the concept may alter in future.

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