HIGH-COURT

Alan Rafferty Ollie Winters Jade Du Berry

The High Court has confirmed that HMRC do not have a veto over restructuring plans. Alan Rafferty, Jade Du Berry and Ollie Winters (Milbank) examine the implications of Waldorf, including HMRC’s constitutional arguments, the treatment of tax losses and the evolving approach to cross-class cram downs.

Liam McKay

Adam Craggs

Adam Craggs and Liam McKay (RPC) review lessons from several important procedural decisions and a successful challenge to HMRC’s approach to subject access requests.

High Court sanctions Part 26A restructuring plan despite valuable tax losses

High Court dismisses JR challenge to HMRC data-sharing with Spain

High Court considers subject access rights under UK GDPR in context of tax enquiry.

Liam McKay

Adam Craggs

This year has seen decisions on anonymity in tax appeals, cross-examination in judicial review, and failing to comply with tribunal directions. Adam Craggs and Liam McKay (RPC) investigate.

Anthony Inglese

Dame Sarah Falk talks to Anthony Inglese CB about her progression from life as a tax practitioner to becoming a senior member of the judiciary.

Constantine Christofi

Adam Craggs

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

Jolyon Maugham

Jolyon Maugham QC (The Good Law Project) explains why he has issued proceedings in the High Court against Uber to ensure that it pays VAT on supplying transportation services.