LITIGATION

Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) give a festive appraisal of the key case decisions in 2023 affecting private clients.

Jason Collins

Ravi Ahlawat

Have HMRC been pushing their interpretation of tax legislation too far? Jason Collins and Ravikaran Ahlawat (DLA Piper) look at lessons from some of this year’s key judgments.

Ian Zeider

Emily Clark

Emily Clark and Ian Zeider (Travers Smith) revisit the Upper Tribunal’s salaried members judgment in BlueCrest, focusing on what it means for LLPs. Is there now more scope to claim ‘significant influence’, but perhaps less certainty of being on the right side of the line?

Ben Blades

Recent cases have diverged on the question of whether HMRC must establish that carelessness caused a loss of tax, writes Ben Blades (Gray’s Inn Tax Chambers).

Hugh Gunson

Louise Paterson

With HMRC’s scrutiny of taxpayers’ domicile status showing no signs of abating, Hugh Gunson and Louise Paterson (Charles Russell Speechlys) examine key lessons from recent case law.

Karmjit Mader

Annis Lampard

Annis Lampard and Karmjit Mader (Deloitte) provide a back to basics guide to HMRC’s framework for resolving civil tax disputes.

Kelly Stricklin-Coutinho

New guidance has been issued on the conduct of proceedings in the Upper Tribunal. Kelly Stricklin-Coutinho (39 Essex Chambers) examines what’s changed.

Sophie Rhind

Victoria Braid

Sophie Rhind and Victoria Braid (Macfarlanes) examine a recent case in which the tribunal takes a tough approach to HMRC’s failure to comply with an unless order.

Nuel Oji

Stuart Walsh

Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.

Lauren Redhead Emily Burke Clara Boyd

Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.

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