Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.
The burden of proof as regards the taxpayer behaviour, late appeals and cautionary tales for IHT planning are among the topics featuring in this month’s review by Edward Reed and Tristan Honeyborne (Macfarlanes).
HMRC appears to view many penalty appeals as a ‘second bite of the cherry’, even where the tribunal has not considered the earlier decision, writes Anastasia Nourescu (Stewarts).
Helen Adams (BDO) considers the extent to which taxpayers may have a reasonable excuse if they are affected by the coronavirus pandemic and the UK’s lockdown.
A report by Tolley®Guidance on making appeals and applications to the First-tier Tribunal during the Covid-19 pandemic, with insight on appealing to the Upper Tribunal and judicial review.
Andrew Goldstone (Mishcon de Reya) believes that a recent case raises concerns over HMRC’s approach to litigation and illustrates the need for change in the EIS legislation.