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Litigation
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LITIGATION
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’.
A reasonable excuse?
Helen Adams
Youcef Toumi
Helen Adams and Youcef Toumi (BDO) examine the current state of the legislation and case law on reasonable excuse, including how the concept may alter in future.
Hely-Hutchinson: was HMRC merely unfair or ‘conspicuously unfair’?
Michael Sherry
What is ‘conspicuously unfair’? The Court of Appeal disagrees with Whipple J, but Michael Sherry (Temple Tax) thinks it was unfair.
SAE Education Ltd: Court of Appeal defines ‘colleges’ of universities
Robert Holland
Laurie Pay
The Court of Appeal judgment in the case of
SAE Education Ltd
considers how to identify ‘colleges’ of universities, which can exempt their courses from VAT. Laurie Pay and Robert Holland (Deloitte) review the impact of the decision.
Supreme Court upholds barring order against HMRC
Gary Barnett
Heather Rowlands
Heather Rowlands and Gary Barnett (Simmons & Simmons) review
BPP Holdings
and its practical implications for the standard of conduct to be expected of HMRC and other public bodies when conducting litigation.
Logfret: successfully challenging excise duty assessments
Charlotte Brown
Charlotte Brown (Northgate Tax Chambers) examines a recent First-tier Tribunal decision that has provided some welcome clarification regarding the application and scope of the HMDP regulations.
Reeves and CGT holdover relief: better off alone?
Paul Davison
Calum Young
Paul Davison and Calum Young (Freshfields Bruckhaus Deringer) examine a recent tribunal decision which placed pivotal importance on the residency of the taxpayer’s spouse.
Jazztel: restitution and retrospectivity
Rory Cochrane
Rory Cochrane (Devereux Chambers) reviews a recent High Court judgment which was a partial success for a stamp taxes group litigation test claimant.
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51
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
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
NEWS
Read all
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC phase in mandatory payrolling of benefits from April 2027
ATED pre-return banding checks
Coding out winter fuel payment charge
Pensions advisers urge rethink on IHT
CASES
Read all
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
HMRC v GCH Corporation Ltd and others
Barclays Services Corporation and another v HMRC
Other cases that caught our eye: 19 June 2026
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Consultation tracker
Lifeplus Europe Ltd v HMRC
Sintra, Hall and the reshaping of HMRC’s burden of proof
Management rollovers and share-for-share exchange relief
The UK’s tax certainty problem