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TAX POLICY ADMINISTRATION
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
It looks like any tax motivation is becoming fair game, writes Eloise Walker (Pinsent Masons).
The contentious tax world in 2024
Adam Craggs
Liam McKay
This year has seen decisions on anonymity in tax appeals, cross-examination in judicial review, and failing to comply with tribunal directions. Adam Craggs and Liam McKay (RPC) investigate.
In conversation with... Malcolm Gammie CBE KC
Anthony Inglese
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC of One Essex Court talks to Anthony Inglese about life at the Tax Bar and beyond. He is a widely respected silk with extensive experience in tax litigation and advisory work, having represented both HMRC and taxpayers in a number of high-profile tax cases.
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
Rebekka Sandwell
Recent cases suggest a worrying trend towards HMRC adopting a more combative approach to judicial review proceedings, write Robert Waterson and Rebekka Sandwell (Eversheds Sutherland).
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
Sam Wardleworth
Steven Porter
The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).
The new Overseas Workday Relief regime: worse than before?
Steve Wade
The proposed reforms to Overseas Workday Relief could have greatly
simplified administration for taxpayers, agents and HMRC. Steve Wade (EY)
examines what’s actually been proposed.
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Tanja Velling (Slaughter and May) reviews a significant FTT decision in
which the taxpayers were denied interest deductions on a loan created in an
intra-group reorganisation under the unallowable purpose rule.
AI in tax administration: the need for taxpayer safeguards
Kunal Nathwani
There are questions over the use of AI by HMRC under the existing legislation
and the adequacy of current taxpayer safeguards, writes Kunal Nathwani
(Kirkland & Ellis).
Tax, memory and the written record: revisiting Gestmin
Gerald Montagu
Elmira Jazottes
Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.
Criminal prosecutions: nobody expects the (tax) inquisition
Siobhan Gillespie
George Gillham
George Gillham and Siobhan Gillespie (Fieldfisher) assess HMRC’s track record.
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EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
HMRC manual changes: 13 December 2024
Scottish and Welsh Budget announcements
Lineker case settled
Anglesey Freeport: special tax sites designated
New overlap relief calculator
CASES
Read all
C Hoyle and others v HMRC
Other cases that caught our eye: 13 December 2024
Five key cases of 2024
Stage One Creative Services Ltd v HMRC
R Grint v HMRC
IN BRIEF
Read all
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
Time for a replacement wealth tax?
Refinitiv: not so clear cut
MOST READ
Read all