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Litigation
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LITIGATION
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.
Discovery
Andrew Hubbard
Andrew Hubbard (LexisNexis) examines the evolution and current state of the law on discovery, and asks whether a fundamental rethink is required in light of making tax digital.
Why I’m challenging Uber
Jolyon Maugham
Jolyon Maugham QC (The Good Law Project) explains why he has issued proceedings in the High Court against Uber to ensure that it pays VAT on supplying transportation services.
Tax law rewrite: Scambler on looking back to ICTA 1988
Rupert Shiers
Julian Brown
In
Scambler v HMRC
, the Upper Tribunal sets out when it is permissible to look to the previous legislation to help interpret Tax Law Rewrite statutes. Rupert Shiers and Julian Brown (Hogan Lovells) review the decision.
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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
Fixing the FIG regime before extending it