LITIGATION

Geoff Lloyd and Paul Dennis (EY) examine how ADR is working for large businesses

James Bullock examines HMRC's consultation on closure rules and finds the proposals amount to a staggering 'inequality of arms'.

Patrick Cannon comments on the impact of a recent decision of the European Court of Human Rights.

Practitioner views on the Autumn Statement:

• Helen Lethaby (Freshfields Bruckhaus Deringer) examines the impact on big business;
• Simon McKie (McKie & Co) reviews the private client perspective;
• James Bullock (Pinsent Masons) considers enforcement and compliance issues;
• David Whiscombe (BKL Tax) assesses the impact on SMEs;
• John Whiting (OTS) gives the Office of Tax Simplification’s view; and
• John Hawksworth (PwC) provides an economic perspective.

HMRC’s high profile clamp-down on suspected tax avoidance has pushed the backlog of tax disputes waiting to be heard to a new record high of 27,246, with a particular surge in the number of high-value cases lodged with the Upper Tax Tribunal, according to law firm Pinsent Masons.

Alternative dispute resolution processes to manage tax disputes have been used by HMRC as ‘business as usual’ for over a year. Peter Nias (Pump Court Tax Chambers) reports

Michael Thomas (Gray’s Inn Tax Chambers) reviews the lessons from recent case law.

A recent survey of senior in-house tax professionals reveals dissatisfaction with HMRC’s conduct in dealing with and resolving tax disputes, writes Liesl Fichardt (Clifford Chance)

Taxpayers increasingly need to rely on statements made by HMRC which do not have the force of law, such as HMRC clearances given to a taxpayer or HMRC guidance. In this back-to-basics guide, Christopher Harrison and David Stainer (Allen & Overy) provide an overview of the principles which govern a taxpayer’s ability to rely on written statements by HMRC, particularly on legitimate expectation.