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Litigation
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Litigation
LITIGATION
HMRC’s Litigation and Settlement Strategy: overdue for reform
Waqar Shah
HMRC have indicated that they intend to update their litigation and settlement policy later this year. Waqar Shah (Kingsley Napley) considers why the policy is ripe for change.
A year at the Tax Bar in 2025
David Yates
David Yates KC (Pump Court Tax Chambers) reflects on a year marked by
unpredictable litigation, shifting private client rules and the evolving realities
of practice at the Tax Bar.
Medpro: better late than never
Stacey Cranmore
Medpro
frees the tribunal from Martland’s fetters, writes Stacey Cranmore
(Pump Court Tax Chambers).
Tax and the City review for March 2025
Mike Lane
Zoe Andrews
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in
Lloyds Asset Leasing
and
Royal Bank of Canada
, as well
as HMRC’s plans to update guidance on the salaried member rules.
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
Kyle Rainsford
RBC
reopens some old
Ramsay
uncertainties. Victoria Hine and
Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.
Findings of fact are stubborn things: A Taxpayer v HMRC
Dominic Lawrance
Catrin Harrison
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys)
consider the implications of the Court of Appeal judgment.
Legal certainty and the Inco principle
Dr Michael Taylor
Dr Michael Taylor (PwC) examines three recent cases where the FTT ignored the plain wording of legislation.
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haughey
David Haworth
David Haworth and David Haughey (Freshfields) examine the implications of the Court of Appeal’s decision for businesses which are potentially within the scope of the UK’s salaried member rules.
Tax, memory and the written record: revisiting Gestmin
Gerald Montagu
Elmira Jazottes
Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.
Rebel without a causal link: HMRC’s position on proving carelessness
Sophie Rhind
Victoria Braid
Mainpay
should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
Go to page
of
51
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
HMRC confirm transitional approach to Pillar Two filing penalties
CIOT urges reform of CIS landlord payment rules
HMRC publish capital v revenue expenditure toolkit
New SDLT guidance published
Updated Directions on employee expenses
CASES
Read all
Swiss Centre Ltd v HMRC
L Henry v HMRC
Winchester City Council v HMRC
Other cases that caught our eye: 3 July 2026
HMRC v HFFX LLP; Atkins and others v HMRC
IN BRIEF
Read all
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
MOST READ
Read all
Consultation tracker
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
HMRC manual changes: 26 June 2026