What’s in your in-tray?
I currently have a variety of matters ranging from finalising submissions to the Court of Justice of the European Union for Mercedes Benz Financial Services through to issues arising from the Murray decision. Since that decision HMRC has been looking far more aggressively at EBTs and remuneration trusts.
What recent tax cases have caught your eye and why?
The Littlewoods compound interest case at the Court of Appeal and HMRC’s decision to raise a 45% corporation tax charge caused a stir (which was recently challenged in the Six Continents case). I await the Supreme Court decision with interest. The Ralph Hely-Hutchinson decision showed how important the courts can be in ensuring that HMRC acts fairly in its dealings with taxpayers.
What’s on your tax wishlist?
Better guidance to correct the mess created by the diverted profits tax (DPT). On reflection whilst...
