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APPEALS


Reasonable excuse

Reasonable excuse and special circumstances

Burden of proof in a refund claim

Stefano Mariani summarises ‘a cautionary tale of wide judicial latitude in statutory construction’ in Wintershall

Validity of VAT assessment

Hearing in the absence of the taxpayer and scope of an information notice

HMRC witnesses

Whether reasons for s 80 claim could be amended

James Bullock considers how effective the new ‘accelerated payments’ powers granted to HMRC will be in curbing tax avoidance schemes.

The Upper Tribunal has now handed down the eagerly awaited judgment in HMRC v Murray Group Holdings and others, better known as ‘the Rangers case’. Robert Waterson and Adam Craggs review the lessons from the decision, which resulted in a loss for HMRC in its campaign against EBTs that it is likely to appeal.

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