LITIGATION

As the dispute between PGMOL and HMRC goes back to round one, counsel for the taxpayer, Georgia Hicks (Devereux Chambers) and Jonathan Peacock QC (11 New Square), consider what the Court of Appeal judgment means for taxpayers in the employment status debate.

Oliver Marre

Oliver Marre (5 Stone Buildings) discusses the TOAA provisions in the light of the Fisher decision and asks: what should taxpayers do now to avoid penal income tax charges on offshore transfers?

Jon Preshaw

Craig Thomson

Craig Thomson (CSM Tax Consulting) and Jon Preshaw (Jon Preshaw Tax Ltd) examine a recent tribunal decision that provides useful guidance on HMRC information requests and closure notices in the context of DPT enquiries.

Michael Blackwell

Dr Michael Blackwell (London School of Economics) discusses the findings of the IFS Tax Law Review Committee’s recently published report.

Heather Self

Hannah Hurley

Heather Self and Hannah Hurley (Blick Rothenberg) examine the key points and the broader implications of the recent Court of Appeal decision.

Sam Wardleworth

Steven Porter

Steven Porter and Sam Wardleworth (Pinsent Masons) examine recent cases that suggest a growing reluctance on the part of the courts to declare notices invalid for minor HMRC errors.

Constantine Christofi

Robert Waterson

Recent trends in the contentious tax world, by Robert Waterson and Constantine Christofi (RPC).

Matthew Greene

Ian Hyde

Ian Hyde and Matthew Greene (Osborne Clarke) explain the basics of legal professional privilege and consider related practical issues in a tax context.

Darren Oswick

Matthew Norris

Darren Oswick and Matthew Norris (Simmons & Simmons) review a recent decision which suggests that insufficient attention has been paid to the ‘profit’ element of the earnings definition.

Clara Boyd

Catherine Robins

The KSM decision offers some glimmers of hope to those who think the FTT should have jurisdiction to consider incidental public law issues, write Clara Boyd and Catherine Robins (Pinsent Masons).

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