LITIGATION

Recent trends in the contentious tax world, by Robert Waterson and Constantine Christofi (RPC).

Ian Hyde and Matthew Greene (Osborne Clarke) explain the basics of legal professional privilege and consider related practical issues in a tax context.

Darren Oswick and Matthew Norris (Simmons & Simmons) review a recent decision which suggests that insufficient attention has been paid to the ‘profit’ element of the earnings definition.

The KSM decision offers some glimmers of hope to those who think the FTT should have jurisdiction to consider incidental public law issues, write Clara Boyd and Catherine Robins (Pinsent Masons).

A recent Court of Appeal judgment has narrowed the VAT payments exemption. Richard Iferenta and Anthony Harb (KPMG) assess the impact and call on the government to widen the scope of the UK’s exemption for the post-Brexit world.

The Supreme Court has handed down its third judgment in the long-running FII GLO case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.

Don Morley, Yvonne Cypher and Basim Khattab (PwC) explain the importance of businesses retaining documentation of commercial decision making as HMRC increasingly focuses on areas of international tax risk.

Marika Lemos (Devereux Chambers) and James Austen (Collyer Bristow) assess the impact of an important Upper Tribunal decision.

Barrister Oliver Marre (5 Stone Buildings) reflects on the use of judicial review as a key safeguard on HMRC’s powers.