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Litigation
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LITIGATION
Tax indemnities: lessons from recent litigation
Charles Osborne
Richard Jeens
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.
Conegate: privilege in tax avoidance disputes
Stuart Walsh
Jason Collins
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.
Hicks: discover the limits
Constantine Christofi
Adam Craggs
Adam Craggs and Constantine Christofi (RPC) review a recent tribunal decision which considers disclosure and the practical effect of
Sanderson
.
Managed service companies: involuntary involvement
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
.
Bilta v RBS: litigation privilege and tax investigations
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).
VAT briefing for March 2018
Gary Barnett
Martin Shah
Martin Shah and Gary Barnett (Simmons & Simmons) review the latest VAT developments that matter.
Trigg: QCBs and the limits of purposive interpretation
Mark Brailsford
James Hamon
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.
HMRC v Lomas and others: an interesting case
Heather Self
Heather Self (Blick Rothenberg) assesses the impact of the recent Court of Appeal judgment in
Lomas
on whether interest is ‘short’ or ‘yearly’.
Contentious tax in 2017
Richard Jeens
Richard Jeens (Slaughter and May) reviews a busy year for tax disputes, both in terms of the scale and number of DPT and transfer pricing enquiries and a number of significant court decisions.
Supreme Court ruling in Littlewoods
Nick Skerrett
Nick Skerrett (Simmons & Simmons) examines the background, issues and impact of the much awaited decision on ‘adequate indemnity’.
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51
EDITOR'S PICK
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
1 /7
Medpro: better late than never
Stacey Cranmore
2 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
3 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
4 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
5 /7
Understanding the FIG regime
Jo Bateson
6 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
7 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
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
NEWS
Read all
HMRC manual changes: 21 November 2025
Tax stability key for internationally mobile individuals
HMRC campaign on management expenses
Partnership NICs potentially scrapped, but concerns remain
Set tax thresholds at real values, says IFS
CASES
Read all
HMRC v Moir Management Services Ltd
1st Alternative Medical Staffing Ltd v HMRC
J Dreyer v HMRC
Other cases that caught our eye: 21 November 2025
Saunders v HMRC
IN BRIEF
Read all
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
Yet more Budget speculation
Fixing the FIG regime before extending it
The new non-dom rules
MOST READ
Read all
Yet more Budget speculation
Meet in the middle: HMRC’s transfer pricing settlement policy
TSI Instruments Ltd v HMRC
Saunders v HMRC
The new non-dom rules