UPPER-TRIBUNAL

Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.

Mike Lane

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) provide their unique perspective on the impact of recent rulings from the higher courts and the OECD’s latest findings on the UK’s rising tax burden on labour.

Julius Berling

Liesl Fichardt

Liesl Fichardt and Julius Berling (Quinn Emanuel) assess the Upper Tribunal ruling in Lycamobile and its implications beyond telecoms.

Paul Farey

Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.

Abigail McGregor

Jake Landman

Jake Landman and Abigail McGregor (Pinsent Masons) revisit the discretionary regime allowing HMRC to suspend penalties for careless inaccuracies, in light of recent Upper Tribunal guidance.

Henry Bennett-Gough

Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in Boston Consulting Group and its implications for mixed member LLP structures.

Liam McKay

Adam Craggs

The Court of Appeal restores a strict approach to late appeals, leaving taxpayers facing the familiar Martland hurdle once again, write Adam Craggs and Liam McKay (RPC).

Cristy Ajediti

Helen Coward

Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.

Peter North

Rob Sharpe

Rob Sharpe and Peter North (Cleary Gottlieb) examine a recent Upper Tribunal ruling on the taxation of stock appreciation rights – a decision that introduces fresh uncertainty for arrangements falling outside ITEPA 2003 Part 7.

Sinisa Butina

Angela Savin

Angela Savin and Sinisa Butina (KPMG) examine the basis of the Upper Tribunal’s reasoning in Scatola and the broader ramifications for taxpayers seeking certainty and finality to their SDLT affairs.

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