LITIGATION

Anastasia Nourescu and David Pickstone (Stewarts) consider the pitfalls of HMRC’s newly published ADR guidance and how taxpayers and advisers should approach ADR going forward.

Craig Kirkham-Wilson

Craig Kirkham-Wilson (Simmons & Simmons) reviews a recent decision of the Upper Tribunal on staleness and Supreme Court precedent.

Constantine Christofi

Adam Craggs

Whilst taking professional advice will usually mean a taxpayer has taken reasonable care, not taking advice does not necessarily mean a taxpayer has been careless, write Adam Craggs and Constantine Christofi (RPC).

Folajimi FJ Akinla

Folajimi FJ Akinla (PwC) reviews a recent CJEU ruling which curtails the DAC 6 notification obligation concerning certain tax planning cross-border arrangements.

Paul Farey

Paul Farey (AECOM) considers the impact of a Court of Appeal decision in the long-running Urenco capital allowances case.

Dominic Stuttaford

Aiden Hepworth

Two recent cases provide a reminder of the extent to which taxation outcomes can depend on other areas of law and demonstrate that HMRC will not be limited to ‘pure’ tax law arguments on appeal, write Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright).

Patrick Cannon

Patrick Cannon (Cannon Chambers) examines a recent tribunal decision on self-assessed mixed-use SDLT and the broader issue of reliance on HMRC’s published guidance.

Gideon Sanitt

Hit lists and man-marking.

Peter Adriaansen

Pierre-Antoine Klethi

This judgment deals a blow to the European Commission’s state aid investigations concerning tax rulings on transfer pricing, writes Pierre-Antoine Klethi and Peter Adriaansen (Loyens & Loeff).