Legal professional privilege for tax advice should be abolished, according to Deloitte’s head of tax policy, because it is usually only claimed in cases of the most ‘egregious’ tax planning.
Two thirds of applications accepted as part of a two-year trial of alternative dispute resolution (ADR) resulted in the disputes being either fully or partially resolved, HMRC said.
Decision could have ‘significant ramifications’ for taxpayers who have entered into similar arrangements, says employment tax expert
Employer deducting tax at basic rate
Angela Savin reviews the decision of the Upper Tribunal in Noor, and explains why we are back to where we were before Oxfam.
SI 2013/477
Ryan Hawthorne examines the Court of Appeal decision in Daniel.
Reader feedback from Nicholas Jordan and David Harkness on the problems of trying to apply GLO procedures to the tribunal lead case rule.
The recent decision in MJP Media highlights the difficulties of persuading a court of appeal to interfere, where the First-tier Tribunal has made findings of fact on the available and limited evidence. Liesl Fichardt identifies the lessons for taxpayers.
Michael Anderson and Kevin Elliott compare and contrast the rule 18 process for bringing lead cases to the FTT with the more sophisticated GLO process which exists in the High Court to demonstrate how the use of rule 18 might be made more efficient and effective.