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Litigation
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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
Zoe Andrews
Mike Lane
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
Kyle Rainsford
Victoria Hine
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
Catrin Harrison
Dominic Lawrance
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 Haworth
David Haughey
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
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
Professional bodies warn against UTT expansion
Close company reporting: ‘benefits lost in a sea of data’
HMRC clarify CIS treatment of pure financing arrangements
HMRC guidance gives comfort on management rollovers
Further compensation payments exemption
CASES
Read all
Lifeplus Europe Ltd v HMRC
MyPay Ltd v HMRC
WWM (Harrogate) LLP v HMRC
Other cases that caught our eye: 12 June 2026
Bagshaw Ltd v Revenue Scotland
IN BRIEF
Read all
Information notices
Management rollovers and share-for-share exchange relief
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
MOST READ
Read all
HMRC clarify CIS financing positions
Ask an expert: Dividend planning under the new close company reporting regime
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Consultation tracker
One minute with… Jon Claypole