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IN BRIEF

Views on recent developments in tax.

A reminder of some basic principles of litigation – and a missed opportunity to tackle Hardy.
The Upper Tribunal suggests a new dimension to the awareness issue.
Private equity managers will need to look closely at the proposed minimum substance rules.
High energy prices, in the money hedges and another special purpose tax for the UK.
If you play with fire...
The tribunal takes a broad approach to applying an EU tax directive in the UK despite Brexit.
Why the current rules are past their ‘best before’ date.
Some helpful observations from the Upper Tribunal in Tooth which may have gone unnoticed.
The European Commission takes its first steps towards implementing the OECD’s two pillar rules.
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