APPEALS209CA89E-4112-4CDC-B8DB-D791CE3CF498

Constantine Christofi Craig Kirkham-Wilson Lauren Trask

Form over influence? Constantine Christofi, Craig Kirkham-Wilson and Lauren Trask (EY) examine the Supreme Court’s decision in BlueCrest and what it means for Conditions A and B of the salaried members rules.

Jade Du Berry Alan Rafferty Ollie Winters

The High Court has confirmed that HMRC do not have a veto over restructuring plans. Alan Rafferty, Jade Du Berry and Ollie Winters (Milbank) examine the implications of Waldorf, including HMRC’s constitutional arguments, the treatment of tax losses and the evolving approach to cross-class cram downs.

Glyn Edwards

Glyn Edwards (MHA) examines an apparent increase in HMRC strike-out applications and why many are failing to clear the tribunal’s high threshold.

Upper Tribunal rejects taxpayer allegations of bias as totally without merit

FTT dismisses taxpayer’s appeal to adduce expert evidence about meaning of ‘security’

LBTT lease extension appeal sisted pending Archer: There is an unresolved issue concerning the operation of the Scottish Land and Buildings Transaction Tax which concerns the incidence of the tax where the term of a lease is extended by a Minute of...

FTT refuses to stay tax appeals behind related judicial review proceedings

HMRC’s unreasonable conduct justified standard costs

GLO test case ruling not binding where legal basis later shown to be wrong

Appeal allowed against HMRC allocating scheme reference numbers under DOTAS

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