JUDICIAL-REVIEW

HMRC’s revised view of UK–Spain treaty residence not amenable to judicial review

Judicial review determining tax residency: K (oao R Houldsworth) v HMRC [2025] EWHC 2848 (Admin) (4 November) revisits an issue which many people might have thought had gone away: the extent to which the (former) IR20 booklet can be relied on when...

Judicial review concerning legitimate expectation over domicile status

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...

Upper Tribunal decides that HMRC lawfully refused late claim under SP 5/01

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.

What is a bar?

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.

Adam Craggs

Liam McKay

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.

Paula Ruffell

Astrid Vroom

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.

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