APPEALS

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.

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).

Malcolm Gammie CBE KC

The Supreme Court stands at the head of the UK’s judicial appeals system. Malcolm Gammie CBE KC (One Essex Court) examines when permission to appeal to the Supreme Court is likely to be granted, and considers how taxpayers and HMRC are faring in securing permission.

Thomas Chacko

The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).

Sophie Rhind

Sophie Rhind (Macfarlanes) reports on the game changing amendment to rule 24 of the Upper Tribunal rules.

Constantine Christofi

Robert Waterson

Recent trends in the contentious tax world, by Robert Waterson and Constantine Christofi (RPC).

Victor Cramer

What rights do those indirectly affected by tax disputes have if they disagree with the outcome?

Constantine Christofi

Adam Craggs

Your quarterly review of developments in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).

Constantine Christofi

Adam Craggs

Your quarterly review of developments in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).

Catherine Robins

Sam Wardleworth

Catherine Robins and Sam Wardleworth (Pinsent Masons) review an interesting Upper Tribunal decision on the test for trading, 'golden contracts' and the availability of enterprise zone allowances and legitimate expectation.

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