APPEALS

A decade of tax decisions examined by Michael Conlon QC (Temple Tax Chambers).

Ami Jack

Ami Jack (Smith & Williamson) sets out a guide to the main political parties’ tax proposals in the run-up to the general election.

Steven Porter

Catherine Robins

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).

Constantine Christofi

Robert Waterson

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).

Keith Gordon

The loan charge has driven a coach and horses through the statutory safeguards, writes barrister Keith Gordon (Temple Tax Chambers).

Charlotte Anderson

Emily Szasz

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

David Pett (Temple Tax Chambers) argues that outstanding loan charges should be pursued both as a matter of law and social policy.

Michael Thomas KC

Barrister Michael Thomas (Pump Court Tax Chambers) believes there is a disturbing trend in our tax jurisprudence: an increasing number of important decisions made by HMRC are only capable of being challenged on a judicial review basis.

Cristiana Bulbuc

Lee Ellis

Hyrax and Curzon Capital Ltd consider for the first time the provisions governing HMRC’s ability to seek an order that a scheme is notifiable under DOTAS. Lee Ellis and Cristiana Bulbuc (Stewarts Law) consider the practical implications.