The courts are reluctant to tie HMRC down to its assurances unless made in the clearest and most unambiguous circumstances, as a recent case illustrates.
James Quarmby argues that strict liability offences for tax evasion have no place in our legal system.
Peter Mason (Rosetta Tax), David Jordorson (Association of British Insurers) and Hamish Garnett (MetLife) review the recent Aspiro decision and assess its impact on UK insurance supply chains and insurance intermediary services generally.
The Court of Appeal has handed down its judgment in the Prudential case, in what is hoped to be one of the final steps of this long lasting action between taxpayers invested in cross border portfolio holdings and HMRC. Simon Whitehead and Philippe Freund (Joseph Hage Aaronson), who acted for the taxpayers, summarise the outcome of this judgment and explain why it has taken so long.
The Court of Appeal judgment in The Open University raises the question as to what can be defined as education for VAT purposes. Laurie Pay and Robert Holland (Deloitte) review the impact of the decision.
Tori Magill and Anne-Marie Ottaway (Pinsent Masons) look at the recent controversy and the fine lines between tax planning, avoidance and evasion.
Claim for judicial review of an advance payment notice rejected
Nick Skerrett (Simmons & Simmons) examines the Court of Appeal’s decision in BPP Holdings, where HMRC was barred from VAT proceedings under the Mitchell approach.
BPP v HMRC tells us that HMRC must comply with rules and directions issued by the tax tribunals, reports Robert Waterson (RPC).