LITIGATION

FII Group Litigation – grant of summary judgment

BDO, the liquidator in Murray Group Holdings (better known as ‘the Rangers case’), has submitted its appeal against the Court of Session’s ruling of 4 November 2015 on the company’s use of EBTs, seeking leave to appeal to the Supreme Court.

John Brinsmead-Stockham

Lord Carnwath’s ‘brief comment’ in Pendragon addresses the appellate jurisdiction of the Upper Tribunal and Court of Appeal in tax appeals. John Brinsmead-Stockham (Tax Chambers, 11 New Square) analyses its impact.

Cathya Djanogly

Tax avoidance and retrospective legislation

Santhie Goundar

According to research by Thomson Reuters, companies in the FTSE 100 have set aside £1.66bn to cover the cost of tax litigation – a fall of 31% from the £2.39bn set aside for tax litigation purposes by FTSE 100 companies in 2014 – with one company’s tax litigation provisions making up the bulk of

Peter Vaines

The law and practice on discovery assessments has lost its balance and, along with it, any realistic protection for the taxpayer, writes Peter Vaines.

Gideon Sanitt

Gideon Sanitt (Macfarlanes) considers the rise in judicial review applications against HMRC, and the difficulty for taxpayers in holding HMRC to account.

Julian Hickey

Michael Conlon KC

‘They also pay who only sit and wait…’ Michael Conlon QC and Julian Hickey (Temple Tax Chambers) examine the High Court decision in Rowe on the legality of partner payment notices.