Market leading insight for tax experts
Subscribe
Home
Saved articles
Viewed articles
Login
Logout
E-newsletter
Advertise
About us
Help
View online issue
BROWSE BY TOPIC
Corporate Taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect Taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International Taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private Business Taxes
OMBs
Partnerships
Private Client Taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real Estate Taxes
Property taxes
REITs
Stamp Taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
NEWS
CASES
IN BRIEF
ANALYSIS
ONE MINUTE WITH
PEOPLE & FIRMS
TRACKERS
AUTHORS
ISSUE ARCHIVE
BROWSE BY TOPIC
Corporate taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private business taxes
OMBs
Partnerships
Private client taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real estate taxes
Property taxes
REITs
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
Subscribe
Home
Saved articles
Viewed articles
View virtual issue
View online issue
Login
Logout
E-newsletter
Advertise
About us
Help
News
Cases
In brief
Analysis
One Minute With
People & Firms
Trackers
Authors
Issue Archive
SEARCH
Home
Judicial review
Home
Judicial review
JUDICIAL-REVIEW
Legislation day 2025: The APR and BPR reforms: sobering reading
Stuart Maggs
The Government might have consulted but it hasn’t listened.
Rettig: HMRC’s tactical approach to public law challenges
Richard Doran
John Hayton
Principled positions often adopted by HMRC can have the practical effect of
avoiding or otherwise delaying judicial scrutiny of their decision-making process,
write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).
Challenging HMRC’s debt management actions: lessons from Local Fuel
Daniel Williams
Michelle Sloane
A recent High Court decision provides valuable guidance for taxpayers
seeking to challenge enforcement action taken by HMRC’s Debt Management
team, write Michelle Sloane and Daniel Williams (RPC).
Contentious tax quarterly: Spring 2025
Adam Craggs
Liam McKay
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.
Initiative and the tax tribunal: a higher calling?
Bridget Winters
Calum Young
In an adversarial system, when can the tribunal take the initiative and
reach decisions on arguments not made by counsel? Bridget Winters and
Calum Young (Taylor Wessing) investigate.
Other cases that caught our eye: 11 July 2025
Disguised remuneration schemes, end users and judicial review: It is now accepted that most, if not all, disguised remuneration schemes involving the making of loans to employees via an employee benefit trust do not work and that the arrangements...
R (on the application of Rettig Heating Group UK Ltd (in liquidation)) v HMRC
Upper Tribunal decides that HMRC lawfully refused late claim under SP 5/01
Judicial review in tax disputes
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) set out the general principles and the
practical aspects of advancing a judicial review claim.
R (oao) Anglia Ruskin Students’ Union v HMRC
What is a bar?
Tax and the City review for January 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated
guidance on share exchanges.
Go to page
of
5
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC to restart direct recovery of tax debts
Tax agents legislation misses the target, says ICAEW
HMRC issue guidance on international employee earnings
Reserved investor funds: new technical note
Umbrella companies: new HMRC PAYE guidance
CASES
Read all
T Pawar v HMRC
MBP Europe Ltd v HMRC
Circleplane Ltd v HMRC
Other cases that caught our eye: 26 September 2025
The Prudential Assurance Company Ltd v HMRC
IN BRIEF
Read all
More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
MOST READ
Read all
P Collingwood v HMRC
The hidden costs of a cap on lifetime gifting
The future of international tax reform
UK-Vietnam tax treaty updated
The Prudential Assurance Company Ltd v HMRC