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Staleness
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Staleness
STALENESS
View from the Tax Bar in 2023
Laura Poots
Laura Poots (Pump Court Tax Chambers) shares some tips for minimising last minute procedural issues and also reports some positive developments in diversity at the Bar.
Tax and the City review for March 2023
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.
Tax procedure’s dead parrot: staleness and stare decisis
Craig Kirkham-Wilson
Craig Kirkham-Wilson (Simmons & Simmons) reviews a recent decision of the Upper Tribunal on staleness and Supreme Court precedent.
Private client review for June 2022
Edward Reed
Andrew Crozier
Decisions on the validity of discovery assessments and information notices are among the recent developments reviewed by Edward Reed and Andrew Crozier (Macfarlanes).
Contentious tax quarterly
Constantine Christofi
Adam Craggs
Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
Discovery following Tooth: what should advisers do now?
Helen Adams
Helen Adams (BDO) considers the ways the Supreme Court decision will change advisers’ approach to discovery appeals.
Tooth, staleness and protective assessments
Sophie Lloyd
Rob Smith
What does the decision mean for protective assessments?
Discovery assessments: the Supreme Court’s decision in Tooth
Clara Boyd
Ian Robotham
Clara Boyd and Ian Robotham (Pinsent Masons) examine the unanimous decision that clarifies the law in relation to discovery assessments.
Mehrban: staleness takes the biscuit
HMRC can’t wait forever to make a discovery assessment.
Another day, another BBC IR35 case: with a sting in the tail
David Whiscombe
In yet another IR35 case, a tribunal considers the procedural validity of the determinations under which HMRC sought to collect the tax.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
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New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
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Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
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Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
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TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime