Market leading insight for tax experts
View online issue

LITIGATION


The principle of open justice is the overarching theme in this review by Adam Craggs and Harry Smith (RPC).
The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).
Exceptions to the doctrine of precedent do exist but, as a recent case illustrates, they will be rarely applied in practice, write Michael Ridsdale and Gemma Williams (Wedlake Bell).
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and its implications going forward.
Laura Poots (Pump Court Tax Chambers) shares some tips for minimising last minute procedural issues and also reports some positive developments in diversity at the Bar.
The Supreme Court does strive to find a workable and straightforward interpretation of the law, writes Constantine Christofi (EY).
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) give a festive appraisal of the key case decisions in 2023 affecting private clients.
Have HMRC been pushing their interpretation of tax legislation too far? Jason Collins and Ravikaran Ahlawat (DLA Piper) look at lessons from some of this year’s key judgments.
Emily Clark and Ian Zeider (Travers Smith) revisit the Upper Tribunal’s salaried members judgment in BlueCrest, focusing on what it means for LLPs. Is there now more scope to claim ‘significant influence’, but perhaps less certainty of being on the right side of the line?
Recent cases have diverged on the question of whether HMRC must establish that carelessness caused a loss of tax, writes Ben Blades (Gray’s Inn Tax Chambers).
EDITOR'S PICKstar
Top