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LITIGATION
Contentious tax quarterly: Summer 2024
Harry Smith
Adam Craggs
The principle of open justice is the overarching theme in this review by Adam Craggs and Harry Smith (RPC).
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
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).
When does the ratio of a judgment have no precedential value?
Michael Ridsdale
Gemma Williams
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).
Clipperton revisited: open questions
Oliver Marre
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and
its implications going forward.
View from the Tax Bar in 2023
Laura Poots
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.
Tax and the Supreme Court in 2023
Constantine Christofi
The Supreme Court does strive to find a workable and straightforward interpretation of the law, writes Constantine Christofi (
EY).
Private client Christmas case round-up
Catrin Harrison
Dominic Lawrance
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) give a festive appraisal of the key case decisions in 2023 affecting private clients.
Tax controversy in 2023: has inflation of taxing provisions been tamed?
Jason Collins
Ravikaran Ahlawat
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.
Salaried members rules: the position for LLPs after BlueCrest
Ian Zeider
Emily Clark
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?
Carelessness and the requirement of causation
Ben Blades
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).
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
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HMRC manual changes: 19 September 2025
Chancellor commits to business rates reform
CIOT warns of ‘unintended complexity’ in APR/BPR draft legislation
Professional bodies analyse draft Finance Bill legislation
Changing the timing of land remediation relief may prove beneficial, says CIOT
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The Prudential Assurance Company Ltd v HMRC
P Collingwood v HMRC
K (oao Hotelbeds UK Ltd) v HMRC
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SC Arcomet Towercranes SRL
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Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
Tribunal orders HMRC to disclose whether it used AI in R&D claims
Second home dilemma for SDLT
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Tribunal orders HMRC to disclose whether it used AI in R&D claims
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
EV charging added to advisory fuel rates
Budget 2025 set for 26 November
UK-Vietnam tax treaty updated