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LITIGATION
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?
Vitol Aviation, closure notices and DPT enquiries: ‘enough already’?
Jon Preshaw
Craig Thomson
Craig Thomson (CSM Tax Consulting) and Jon Preshaw (Jon Preshaw Tax Ltd) examine a recent tribunal decision that provides useful guidance on HMRC information requests and closure notices in the context of DPT enquiries.
The tax tribunals: the next ten years
Michael Blackwell
Dr Michael Blackwell (London School of Economics) discusses the findings of the IFS Tax Law Review Committee’s recently published report.
Ingenious Film Partners in the Court of Appeal: lights, camera, action!
Heather Self
Hannah Hurley
Heather Self and Hannah Hurley (Blick Rothenberg) examine the key points and the broader implications of the recent Court of Appeal decision.
When is a defective HMRC notice invalid?
Sam Wardleworth
Steven Porter
Steven Porter and Sam Wardleworth (Pinsent Masons) examine recent cases that suggest a growing reluctance on the part of the courts to declare notices invalid for minor HMRC errors.
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50
EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
UK signs new double tax treaty with Romania
Autumn Budget 2024: IHT winners and losers