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Paula Ruffell and Astrid Vroom (EY) consider the implications of Refinitiv to transfer pricing methodologies adopted in multiple years and what this means for APAs and DPT assessments more generally.
The meaning of ‘residence’ for LBTT purposes: A Blue v Revenue Scotland [2023] FTSTC 4 (21 December 2023) is a case on the additional dwelling supplement rules for Scottish land and buildings transaction tax, particularly the rules relating to...
Domicile disputes, exceptional circumstances, judicial review... Edward Reed and Kathryn Hart (Macfarlanes) review recent developments in the private client world.
Jake Landman and Abigail McGregor (Pinsent Masons) review two recent cases exploring the circumstances where a taxpayer can, and can’t, rely on a statement made by HMRC in order to establish a legitimate expectation.
Judge on HMRC’s shoulder? A recent Court of Appeal ruling demonstrates that judicial review remains a vital and effective tool in defending taxpayers’ public law rights, write Adam Craggs and Liam McKay (RPC).
Steven Porter and Sam Wardleworth (Pinsent Masons) provide a refresher guide to these ‘game changing’ regimes.
The KSM decision offers some glimmers of hope to those who think the FTT should have jurisdiction to consider incidental public law issues, write Clara Boyd and Catherine Robins (Pinsent Masons).
Barrister Oliver Marre (5 Stone Buildings) reflects on the use of judicial review as a key safeguard on HMRC’s powers.
Monique van Herksen and Gary Barnett (Simmons & Simmons) examine a recent decision of the CJEU that presents a setback for taxpayers in this developing area of law.