ECHR and double taxation
Process defects and appeals to the FTT
Witness summons and non-resident witnesses
While the much-anticipated decision in Project Blue is unsurprising, the decision raises some points of wider interest, including because HMRC prevailed by using FA 2003 s 75A, the SDLT anti-avoidance rule. Michael Thomas (Gray’s Inn Tax Chambers) reports
Ascertaining undeclared income
Inaccuracy penalties and inappropriate forms
Reliance on adviser and reasonable excuse
In this month’s briefing, Mark Middleditch (Allen & Overy) provides a round-up of recent tax developments affecting the City, including: the decisions in Sir Fraser Morrison (contingent CGT liability for shareholder-director) and Project Blue (SDLT anti-avoidance); new tax relief for corporate rescues; and the Office of Tax Simplification’s report on partnership taxation.
More than 100 UK film scheme investors that have been issued with accelerated payment notices (APNs) demanding payment of disputed tax upfront will be able to challenge the policy in the courts.
Stay of proceedings pending decision by the CJEU