TAX-DISPUTES

Gerald Montagu Evelyne Bagdassarian José Ramón Vizcaíno

A letter from Paris and Madrid, coupled with some reflections on the proposed direct tax Omnibus Directive/Recast DAC 6 Directive and recent Court of Appeal judgments, by Evelyne Bagdassarian, José Ramón Vizcaíno and Gerald Montagu (Stephenson Harwood).

James Le Gallais

Anastasia Nourescu

Parallel HMRC and civil proceedings are best handled not as two separate problems to be dealt with in sequence, but as a single, interconnected strategic challenge, write James Le Gallais and Anastasia Nourescu (Stewarts).

Waqar Shah

HMRC have indicated that they intend to update their litigation and settlement policy later this year. Waqar Shah (Kingsley Napley) considers why the policy is ripe for change.

Ben Elliott

Louis Triggs

Ben Elliott and Louis Triggs (Pump Court Tax Chambers) set out the three conditions for invoking the Inco principle, the factors that determine its application in practice, and the role it may play as Brexit-era drafting and rapid legislative change generate more disputes.

Liesl Fichardt

Emily Au

Liesl Fichardt and Emily Au (Quinn Emanuel) consider the use of AI in tax disputes and the implications for transparency, fairness and taxpayer challenges.

David Whiscombe

Boulting cannot be regarded as a satisfactory case, except as to its outcome in favour of the taxpayer, writes David Whiscombe.

Ravi Ahlawat

Lauren Redhead

Lauren Redhead and Ravi Ahlawat (DLA Piper) consider what to do when HMRC enquire into deal funding, and provide a practical playbook from first request to resolution.

Liam McKay

Adam Craggs

Adam Craggs and Liam McKay (RPC) review some notable rulings on a range of procedural issues, as well as recent changes to the tribunal rules.

Sophie Dworetzsky

A long-awaited report on will reform and the recent announcement on carried interest are among the developments covered in this month’s review by Sophie Dworetzsky (Charles Russell Speechlys).

Liam McKay

Adam Craggs

Adam Craggs and Liam McKay (RPC) examine the current consultation which could help influence HMRC’s future approach to dispute resolution.

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