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DISPUTES

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Damon Wright

Damon Wright (K3 Tax Advisory) examines the Finance Bill provisions.

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Matthew Greene

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Guy Bud

Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision which stresses the need for accountability and transparency from HMRC when issuing determinations.

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Heather Self

Political pressure has resulted in HMRC adopting a slow and cautious decision-making process that remains to this day, writes Heather Self (Blick Rothenberg).

Disclosure: principle of reciprocity

Closure notices relating to a claim for share loss relief were validly made

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Thomas Chacko

In two recent cases, the tribunal approached the question of what was qualifying research in a way that supports taxpayers’ claims, if the right evidence is presented, writes Thomas Chacko (Pump Court Tax Chambers).

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Helen Adams

Helen Adams (BDO) offers some thoughts on the options and challenges posed by the potential reforms.

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Karmjit Mader

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Annis Lampard

Annis Lampard and Karmjit Mader (Deloitte) provide a back to basics guide to HMRC’s framework for resolving civil tax disputes.

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Constantine Christofi

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Adam Craggs

Your quarterly review of developments in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).

EDITOR'S PICK

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Nick Thornton

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Hartley Foster

Hotel La Tour: where next for input tax recovery on share disposals?

Hotel La Tour: where next for input tax recovery on share disposals?

Rupert Shiers , Laura Hodgson

Mandatory agent registration: what we know so far

Mandatory agent registration: what we know so far

Jane Mellor

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Rob Sharpe , Iarlaith McCarthy-Hann

The Pillar Two Side-by-Side package: how UK groups should approach compliance

The Pillar Two Side-by-Side package: how UK groups should approach compliance

Jack Gifford

Share reorganisations: new anti-avoidance rules explained

Share reorganisations: new anti-avoidance rules explained

Peter Morley , Jamie Robson

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Nick Thornton

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Hartley Foster

Hotel La Tour: where next for input tax recovery on share disposals?

Hotel La Tour: where next for input tax recovery on share disposals?

Rupert Shiers , Laura Hodgson

Mandatory agent registration: what we know so far

Mandatory agent registration: what we know so far

Jane Mellor

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Rob Sharpe , Iarlaith McCarthy-Hann

The Pillar Two Side-by-Side package: how UK groups should approach compliance

The Pillar Two Side-by-Side package: how UK groups should approach compliance

Jack Gifford

Share reorganisations: new anti-avoidance rules explained

Share reorganisations: new anti-avoidance rules explained

Peter Morley , Jamie Robson

CASES

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