FIRST-TIER-TRIBUNAL

HMRC’s unreasonable conduct not sufficiently unreasonable for indemnity costs

Tanja Velling (Slaughter and May) reviews a significant FTT decision in which the taxpayers were denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule.

Costs refused because HMRC’s behaviour was not unreasonable.

Adam Craggs

Liam McKay

We are likely to see a consistent increase in the use of mediation in tax disputes. Adam Craggs and Liam McKay (RPC) explain when and how it is in the taxpayer’s interests.

FTT rejects HMRC’s interpretation of contracted out expenditure in R&D rules.

FTT finds that sub-sale avoidance scheme failed.

Paul Farey

Paul Farey (AECOM) considers the impact of the Upper Tribunal’s ruling in the Gunfleet Sands case.

Property transactions not taxable and PPR available.

Ben Blades

Recent cases have diverged on the question of whether HMRC must establish that carelessness caused a loss of tax, writes Ben Blades (Gray’s Inn Tax Chambers).

Anastasia Nourescu

Matthew Greene

Matthew Greene and Anastasia Nourescu (Stewarts) explain what the rule 18 lead case procedure is, review recent case law clarifying its scope and set out a few practical tips for advisers.

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