FTT

Katie Oliver

Gary Barnett

This month’s review by Katie Oliver and Gary Barnett (Simmons & Simmons) covers VAT and transfer pricing after Stellantis Portugal, input tax repayment disputes and a reminder that overcharged VAT cannot normally be reclaimed directly from HMRC by the customer.

Kyle Rainsford

What happens when tax planning appears to exploit a loophole? Kyle Rainsford (Addleshaw Goddard) reviews the courts’ anti-avoidance toolkit following the HC-One SDLT ruling.

Amelia Roffey

Henry Bennett-Gough

Stage three of the RMC test is where the real action now lies, writes Henry Bennett-Gough (Simmons & Simmons).

Rebecca Seeley Harris

Rebecca Seeley Harris (Re Legal Consulting) examines the potential grounds on which HMRC could appeal the judgment.

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).

Victoria Hine Steven Porter Leah Fisher

Recent judgments provide clear warnings that the tribunals will look beyond the contractual labels in offshore arrangements to the underlying reality of who benefits from and controls the workforce, write Leah Fisher, Steven Porter and Victoria Hine (Addleshaw Goddard).

Julius Berling

Liesl Fichardt

Liesl Fichardt and Julius Berling (Quinn Emanuel) assess the Upper Tribunal ruling in Lycamobile and its implications beyond telecoms.

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.

Liesl Fichardt

Emily Au

Liesl Fichardt and Emily Au (Quinn Emanuel) consider the use of AI in tax disputes and the implications for transparency, fairness and taxpayer challenges.

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