LITIGATION

The role of commercial purpose in arm’s length rules is reconsidered by the CJEU, and appears more generous to taxpayers, writes Kelly Stricklin-Coutinho (39 Essex Chambers).

Helen Cox and Kassim Meghjee (Mishcon de Reya) consider the case’s progress through the courts and the practical impact of the Court of Appeal decision.

Richard Jeens

Charles Osborne

Richard Jeens and Charles Osborne (Slaughter and May) explain the practical points to consider both when drafting the tax indemnity and in the management of any subsequent claims.

Jason Collins

Stuart Walsh

Jason Collins and Stuart Walsh (Pinsent Masons) review a recent tribunal case which highlights the practical difficulties of asserting legal privilege where the taxpayer has to explain their motivations behind a transaction.

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) review a recent tribunal decision which considers disclosure and the practical effect of Sanderson.

David Whiscombe

‘One is tempted to say “taxpayers lose hopeless cases” and leave it at that,’ writes David Whiscombe (BKL) in his review of the decision in Christianuyi.

Clare Reeve Curatola

Kate Ison

The decision in Bilta has clarified the scope of privilege in internal investigations undertaken in the context of HMRC enquiries, write Kate Ison and Clare Reeve (Berwin Leighton Paisner).

Martin Shah

Gary Barnett

Martin Shah and Gary Barnett (Simmons & Simmons) review the latest VAT developments that matter.

James Hamon

Mark Brailsford

To QCB or not to QCB? Mark Brailsford and James Hamon (Berwin Leighton Paisner) review the judgment in Trigg on whether bonds were QCBs, and consider the wider impact on statutory interpretation.