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LITIGATION


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).

The Law Society has released a position paper expressing its belief that, in recent years, there has been a tendency on the part of government to allow the rule of law in taxation to risk being eroded in the interests of making the executive more effective, and makes a number of proposals as to h

75 in-house tax directors and heads of tax from large companies share their views on the coalition government's tax policies and priorities for a new government. 

The Coalition Agreement promised that the coalition government ‘will make every effort to tackle tax avoidance’. Graham Aaronson and Steve Bousher (Joseph Hage Aaronson) give an end of term report on the coalition’s record in dealing with tax avoidance
 

Tax fraud involving pension funds

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