LITIGATION

The tribunal has issued its decision in Ingenious Film Partners 2 LLP. Gideon Sanitt (Macfarlanes) reviews the consequences of that decision for investors.

Kevin Offer

Kevin Offer (Gabelle) reviews the case of English Holdings Ltd v HMRC, where corporate losses were claimed against income.

Chris Davidson

The report published last month contains some fascinating detail which throws a light on how HMRC is approaching the task of settling large disputes, writes Chris Davidson CBE (KPMG).

Heather Self

Heather Self (Pinsent Masons) examines the Court of Appeal decision in Greene King PLC and Greene King Acquisitions Ltd v HMRC.

Gary Richards

Gary Richards (Mishcon de Reya) outlines the potential impact of the recent Brisal and KBC Finance Ireland case on the UK, which is complicated by the EU referendum result.

Shiv Mahalingham

Shiv Mahalingham (Duff & Phelps) identifies key changes to international transfer pricing guidance, regulations and case law that have occurred in the past few months.

Adam Craggs

Adam Craggs (RPC) reviews the decision in Mabbutt, which serves as an important reminder of the essential elements of a valid notice of enquiry into an individual’s specific tax return.

Andrew Goldstone

Sarah Albury

Andrew Goldstone and Sarah Albury (Mishcon de Reya) review recent private client tax developments that matter, including the decisions in Miesegaes, Hall, Sparkasse Allgäu and King.

Perminder Gainda

Josh Lom

Josh Lom and Perminder Gainda (Herbert Smith Freehills) consider the decisions in McQuillan and Castledine, where the tribunals took different approaches to the meaning of ‘ordinary share capital’.

Arabella Murphy

Arabella Murphy (Maurice Turnor Gardner) considers the judgment in Bainbridge, where an application to rescind mistaken transfers of farmland to a trust was complicated by the fact that some of the land had been sold.

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