Expert insight on one of the most powerful weapons in HMRC's arsenal
Does the Supreme Court judgment in Pendragon represent a shift of emphasis? Can offshore schemes of the Newey-type scheme survive? Michael Conlon QC and Rebecca Murray (Temple Tax Chambers) examine the impact of recent case decisions on VAT planning arrangements.
In disputes with HMRC, robust professional witness evidence can be a key factor for taxpayer success. Geoff Lloyd and Yvette Adams (EY) review the rules and lessons from case law.
HMRC is unable to answer FOI request on the Lagarde list, writes John Barnett (Burges Salmon).
Tony Beare (Slaughter and May) examines the recent eagerly anticipated First-tier Tribunal decision of Next Brand Ltd v HMRC on dividend boosters.
Jurisdiction of the UT to hear appeals against information notices
HMRC is right to assert that the ‘no possibilities’ test should be applied immediately after the base loss period for losses from 1 April 2006, but wrong to apply it to periods before that date, writes Peter Cussons (PwC).