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APPEALS


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

This year has seen an increasing compliance burden for companies, an expansion of HMRC powers and a reminder of the important role of the courts, write Kate Ison and Jessica Hocking (Bryan Cave Leighton Paisner).

A decade of tax decisions examined by Michael Conlon QC (Temple Tax Chambers).
Ami Jack (Smith & Williamson) sets out a guide to the main political parties’ tax proposals in the run-up to the general election.
The government intends to change the law retrospectively to make it clear that HMRC can use automated processes to issue notices to file returns and to issue penalties, report Catherine Robins and Steven Porter (Pinsent Masons).
The Court of Appeal's recent decision appears to set a high bar for establishing an unlawful breach of a taxpayer’s legitimate expectation, write Robert Waterson and Constantine Christofi (RPC).
The loan charge has driven a coach and horses through the statutory safeguards, writes barrister Keith Gordon (Temple Tax Chambers). 
Emily Szasz and Charlotte Anderson (Freshfields Bruckhaus Deringer) examine the FTT decision on the interaction between domestic appeals and MAPs which are provided for in double tax treaties.
David Pett (Temple Tax Chambers) argues that outstanding loan charges should be pursued both as a matter of law and social policy.
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