TAX-DISPUTES

Jake Landman

Jake Landman and Abigail McGregor (Pinsent Masons) examine what the Supreme Court’s AXA judgment means for the binding effect of group litigation rulings and the importance of defining common issues precisely.

Constantine Christofi Craig Kirkham-Wilson Chris Sanger

New HMRC measures risk cumulative constitutional and practical effects that piecemeal consultation may fail to reveal, write Chris Sanger, Constantine Christofi and Craig Kirkham-Wilson (EY).

Evelyne Bagdassarian Gerald Montagu 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).

Anastasia Nourescu

James Le Gallais

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.

Lauren Redhead

Ravi Ahlawat

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.