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LITIGATION


A step-by-step guide for advisers, by Tolley®Guidance.

The targeted anti-avoidance provisions that contain motive tests are being applied in ways which prevent the tax system from operating effectively, writes Constantine Christofi (RPC).

The result of the BlueCrest appeal represents a good outcome for many businesses structured as LLPs, write Amanda Hardy QC and Oliver Marre (5 Stone Buildings). 
The judgment reads as something of a ‘whitewash’, supporting the Commission on every ground, write Paul Davison and Helen Buchanan (Freshfields Bruckhaus Deringer). 
Georgia Hicks (Devereux Chambers) examines two cases which seek to give authoritative guidance on the application of the Ready Mixed Concrete and business on own account tests.
Oliver Marre (5 Stone Buildings) examines a First-tier Tribunal decision that is important for anyone considering inter-group loan structuring.
Karen Killington (KPMG) considers the impact of a recent case where the CJEU held that a subsidiary was not a fixed establishment.
Angela Savin and Michael Brady (KPMG Law) review the impact of a recent Supreme Court ruling.
A decision of the Upper Tribunal illustrates the difficulties of applying CJEU case law for disputes over pre-Brexit breaches of EU law, write Richard Doran and Davinder Sahota (EY).
Your quarterly review of developments in the contentious tax world, by Jason Collins and Lauren Redhead (DLA Piper). 
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