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APPEALS
The last word on tax appeals
Malcolm Gammie CBE KC
The Supreme Court stands at the head of the UK’s judicial appeals system.
Malcolm Gammie CBE KC (One Essex Court) examines when permission
to appeal to the Supreme Court is likely to be granted, and considers how
taxpayers and HMRC are faring in securing permission.
HMRC v S&L Barnes Ltd
Upper Tribunal allows HMRC’s IR35 appeal.
HMRC v Labeikis and others
High Court strikes out Part 8 loan charge claims.
Case management before the tribunal
Dan Williams
Adam Craggs
Adam Craggs and Dan Williams (RPC) consider the various stages
involved in an appeal to the First-tier Tribunal and focus on the FTT’s case
management powers throughout the process.
Jelly Vine Productions Ltd v HMRC
Taxpayer’s attempt to avoid full IR35 hearing on previously untested procedural grounds is rejected.
No joy for JTIAC: an extension of the unallowable purpose principle
Constantine Christofi
The last in a trilogy of recent Court of Appeal cases on ‘unallowable purpose’ has seemingly extended its ambit yet further, writes Constantine Christofi (EY).
T Watts v HMRC
UT dismisses gilt strips scheme appeal.
Back to basics: Closure notices and the appeals process
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) provide a refresher guide.
L v HMRC
A successful anonymity application.
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Dominic Robertson
Deepesh Upadhyay
Deepesh Upadhyay (Eversheds Sutherland) and Dominic Robertson
(Slaughter and May) examine one of the most important withholding tax
cases in years.
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4
EDITOR'S PICK
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
1 /7
Freebies
David Whiscombe
2 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
3 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
4 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
5 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
6 /7
SDLT: gardens, grounds and grazing
Max Schofield
7 /7
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
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
NEWS
Read all
HMRC manual changes: 18 October 2024
HMRC update ERS guidance for Vermilion
Employment Rights Bill published
Claims and conditions for enhanced rate of AVEC
ISAs and fractional shares
CASES
Read all
Panayi v HMRC
BTR Core Fund JPUT v HMRC
Other cases that caught our eye: 18 October 2024
HMRC v P Gould
Putney Power Ltd and another v HMRC
IN BRIEF
Read all
Bed and breakfasting before the Budget?
NICs and the Budget
Non-dom reforms: shaping the regime
Non-dom reforms: IHT aspects
EU Watch: new mandate, new tax priorities
MOST READ
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One minute with... Dave Chaplin
Budget Responsibility Act brought into force
Case watch
Avoiding avoidance
Direct payment scheme for IHT extended to investment providers