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TAX POLICY ADMINISTRATION


It looks like any tax motivation is becoming fair game, writes Eloise Walker (Pinsent Masons).
This year has seen decisions on anonymity in tax appeals, cross-examination in judicial review, and failing to comply with tribunal directions. Adam Craggs and Liam McKay (RPC) investigate.
Malcolm Gammie CBE KC of One Essex Court talks to Anthony Inglese about life at the Tax Bar and beyond. He is a widely respected silk with extensive experience in tax litigation and advisory work, having represented both HMRC and taxpayers in a number of high-profile tax cases.
Recent cases suggest a worrying trend towards HMRC adopting a more combative approach to judicial review proceedings, write Robert Waterson and Rebekka Sandwell (Eversheds Sutherland).
The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).
The proposed reforms to Overseas Workday Relief could have greatly simplified administration for taxpayers, agents and HMRC. Steve Wade (EY) examines what’s actually been proposed.
Tanja Velling (Slaughter and May) reviews a significant FTT decision in which the taxpayers were denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule.
There are questions over the use of AI by HMRC under the existing legislation and the adequacy of current taxpayer safeguards, writes Kunal Nathwani (Kirkland & Ellis).
Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.
George Gillham and Siobhan Gillespie (Fieldfisher) assess HMRC’s track record.
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