LITIGATION

The role of the Upper Tribunal (UT) in tax appeals has assumed an increased importance, writes Hui Ling McCarthy (11 New Square).

David O'Keeffe

David O’Keeffe (Aiglon Consulting) reviews the tribunal decision in Gas Recovery And Recycle Ltd, which considered whether an anticipatory R&D claim could be made before payment had actually been made.

Shiv Mahalingham

Shiv Mahalingham (Duff & Phelps) identifies key changes to international transfer pricing guidance, regulations and case law that have occurred in the past few months.

Gideon Sanitt

Gideon Sanitt (Macfarlanes) reviews the decision in Ingenious Media and to what extent HMRC will be held to its duty of confidentiality.

Graham Aaronson QC

Graham Aaronson QC (Joseph Hage Aaronson) presents a personal view of tax avoidance in the UK over the past 100 years, looking at the case law and legislation which developed in the first half century, and the social and economic context in which they evolved.

Mark Watterson

Gary Barnett

Mark Watterson and Gary Barnett (Simmons & Simmons) review the recent First-tier Tribunal decision in Dollar Financial on the electronic introductions of customers to a payday lender.

Etienne Wong

Etienne Wong (Old Square Tax Chamber) considers whether the Longridge judgment on ‘relevant charitable purpose’ is the final word on what ‘business’ means for VAT.

Gideon Sanitt

The tribunal has issued its decision in Ingenious Film Partners 2 LLP. Gideon Sanitt (Macfarlanes) reviews the consequences of that decision for investors.

Kevin Offer

Kevin Offer (Gabelle) reviews the case of English Holdings Ltd v HMRC, where corporate losses were claimed against income.

Chris Davidson

The report published last month contains some fascinating detail which throws a light on how HMRC is approaching the task of settling large disputes, writes Chris Davidson CBE (KPMG).

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