LITIGATION

Adam Craggs

Whilst taking professional advice will usually mean a taxpayer has taken reasonable care, not taking advice does not necessarily mean a taxpayer has been careless, write Adam Craggs and Constantine Christofi (RPC).

Folajimi FJ Akinla

Folajimi FJ Akinla (PwC) reviews a recent CJEU ruling which curtails the DAC 6 notification obligation concerning certain tax planning cross-border arrangements.

Paul Farey

Paul Farey (AECOM) considers the impact of a Court of Appeal decision in the long-running Urenco capital allowances case.

Dominic Stuttaford

Aiden Hepworth

Two recent cases provide a reminder of the extent to which taxation outcomes can depend on other areas of law and demonstrate that HMRC will not be limited to ‘pure’ tax law arguments on appeal, write Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright).

Patrick Cannon

Patrick Cannon (Cannon Chambers) examines a recent tribunal decision on self-assessed mixed-use SDLT and the broader issue of reliance on HMRC’s published guidance.

Gideon Sanitt

Hit lists and man-marking.

Peter Adriaansen

Pierre-Antoine Klethi

This judgment deals a blow to the European Commission’s state aid investigations concerning tax rulings on transfer pricing, writes Pierre-Antoine Klethi and Peter Adriaansen (Loyens & Loeff).

Helen Adams

Case law on discovery has continued to evolve after the Supreme Court’s judgment in Tooth, as Helen Adams (BDO) explains.

Simon Whitehead

Did the General Court place too much emphasis on legislative technique and too little on substance and effect? Simon Whitehead (Joseph Hage Aaronson) critiques the state aid decision in UK and ITV v Commission.

Paul Farmer

Simon Whitehead

Paul Farmer and Simon Whitehead (Joseph Hage Aaronson) consider how fiscal state aid issues should be addressed where the national tax provisions creating the aid are not based on a simple exemption from a standard rate but arise from differential rate regimes and asymmetric taxes.

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