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Upper Tribunal
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Upper Tribunal
UPPER-TRIBUNAL
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.
Private client Christmas case round-up
Catrin Harrison
Dominic Lawrance
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) give a festive appraisal of the key case decisions in 2023 affecting private clients.
In conversation with... Rt Hon Lady Justice Falk
Anthony Inglese
Dame Sarah Falk talks to Anthony Inglese CB about her progression from life as a tax practitioner to becoming a senior member of the judiciary.
Capital allowances: a question of design?
Paul Farey
Paul Farey (AECOM) considers the impact of the Upper Tribunal’s ruling in
the
Gunfleet Sands
case.
Certainty vs deterrence: the Supreme Court’s approach to anti-avoidance legislation in Fisher
Ben Elliott
The Supreme Court has effectively left it open to future courts to counteract artificial avoidance, writes Ben Elliott (Pump Court Tax Chambers).
Gunfleet Sands Ltd v HMRC
Capital allowances disallowed for windfarm studies expenditure.
Conduct of proceedings in the Upper Tribunal: new guidance
Kelly Stricklin-Coutinho
New guidance has been issued on the conduct of proceedings in the Upper Tribunal. Kelly Stricklin-Coutinho (39 Essex Chambers) examines what’s changed.
Changes to applying for permission to appeal
Sophie Rhind
Sophie Rhind (Macfarlanes) reports on the game changing amendment to rule 24 of the Upper Tribunal rules.
Is payroll closely connected to welfare work for VAT purposes?
Victor Cramer
Victor Cramer (Stewarts) writes about the potential wider impact of the
Cheshire Centre for Independent Living
decision on payroll services in the care
sector, and questions whether the decision is correct.
Civil or criminal proceedings for serious fraud?
David Sleight
David Sleight (Kingsley Napley) examines a recent Upper Tribunal decision which is important for both tax and criminal litigators alike.
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4
EDITOR'S PICK
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
1 /7
Medpro: better late than never
Stacey Cranmore
2 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
3 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
4 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
5 /7
Understanding the FIG regime
Jo Bateson
6 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
7 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
NEWS
Read all
Post Office Capture Redress Scheme tax exemptions
Chancellor seeks to reassure markets ahead of Budget
Welsh Government publishes second stage of Draft Budget
New regs pave way for delegation of HMRC PAYE functions
HMRC issue coding notices Direction
CASES
Read all
Northumbria Healthcare NHS Foundation Trust v HMRC
J Boulting v HMRC
HMRC v Ducas Ltd
Other cases that caught our eye: 7 November 2025
Illuminate Skin Clinics Ltd v HMRC
IN BRIEF
Read all
Exclusive purposes
‘Partnership NICs’: the impact on the asset management sector
Time to bring back Budget purdah?
Transfer pricing ‘high-value’ intragroup services
Autumn Budget 2025: what tax measures can we expect?
MOST READ
Read all
Tyler Security Ltd v HMRC
Time to bring back Budget purdah?
‘Partnership NICs’: the impact on the asset management sector
Consultation tracker
Eurocent (Buckingham) Ltd v HMRC