COURT-OF-APPEAL

Mike Lane

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) review recent decisions on treaty interpretation, deeming provisions and group litigation orders, alongside HMRC’s latest performance figures.

Louis Triggs

Louis Triggs (Pump Court Tax Chambers) examines the landmark Elborne decision and its wider significance for IHT, trusts and statutory interpretation.

Dr Michael Taylor

Dr Michael Taylor (PwC) explains how the Court of Appeal’s Bolt Services decision narrows the scope of the Tour Operators’ Margin Scheme.

Emily Osborne

‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.

Liesl Fichardt Emily Au Julius Konstantin Berling

Who proves what? Liesl Fichardt, Emily Au and Julius Konstantin Berling (Quinn Emanuel) set out how penalty appeals now divide the burden between HMRC and the taxpayer – and why the line between the two is far from settled.

Georgia Hicks

Following the remitted PGMOL decision, barrister Georgia Hicks (Devereux Chambers) explores where the employment status battleground now lies, and why the third stage of the RMC test has become more important than ever.

Ashley Greenbank

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) analyses the Court of Appeal’s reasoning on treaty abuse, ‘taking advantage’ and the future interpretation of principal purpose tests.

Katharine Wadia

Dominic Stuttaford

The Court of Appeal reins in HMRC’s reading of Rangers, confirming that a genuine EBT loan is not taxable earnings, write Dominic Stuttaford and Katharine Wadia (Norton Rose Fulbright).

Mike Lane

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) provide their unique perspective on the impact of recent rulings from the higher courts and the OECD’s latest findings on the UK’s rising tax burden on labour.

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