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LITIGATION
Capital allowances: what is plant?
Paul Farey
Paul Farey (AECOM) examines two recent decisions that raise some unique considerations and add to the discussion as to what can qualify for plant and machinery allowances.
Urenco: plant and machinery allowances
Will Scott
Susie Brain
Will Scott and Susie Brain (Norton Rose Fulbright) examine an Upper Tribunal decision on the availability of capital allowances in the context of increasingly complex, technical assets used in the power generation industry.
Early stage tax disputes: a practical guide
Sophie Lloyd
Rob Smith
A growing number of taxpayers can expect to be involved in ‘early stage’ tax
disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith)
provide a practical guide for their advisers.
Allam: a case full of interest
Lynnette Bober
Lynnette Bober (Gateley Legal) takes a closer look at a case involving
several diverse issues, not least the difficulties in overturning findings of fact
by the FTT.
Report: Giving evidence from overseas
A Tolley report examines a recent decision of the immigration chamber of the
Upper Tribunal, which has implications for tax hearings.
Tax disputes in 2021: beware the clever procedural skirmish
Jason Collins
Lauren Redhead
Beware the clever procedural skirmish, warn Jason Collins and Lauren Redhead (DLA Piper).
The view from the Tax Bar in 2021
Hui Ling McCarthy KC
With thoughts on virtual hearings from Hui Ling McCarthy QC (11 New Square Chambers).
Contentious tax quarterly: Winter 2021
Constantine Christofi
Adam Craggs
Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
The Court of Appeal’s ruling in PGMOL: seven lessons on mutuality of obligation
Jonathan Peacock QC
Georgia Hicks
As the dispute between PGMOL and HMRC goes back to round one, counsel for the taxpayer, Georgia Hicks (Devereux Chambers) and
Jonathan Peacock QC (11 New Square), consider what the Court of Appeal judgment means for taxpayers in the employment status debate.
The transfer of assets abroad regime after Fisher
Oliver Marre
Oliver Marre (5 Stone Buildings) discusses the TOAA provisions in the light of the
Fisher
decision and asks: what should taxpayers do now to avoid penal income tax charges on offshore transfers?
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50
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
HMRC increase late-payment interest rates
Urgent action could be required on non-dom ‘double remittances’