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LITIGATION


The Supreme Court has handed down its third judgment in the long-running FII GLO case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.
Card image Don Morley Yvonne Cypher Basim Khattab
Don Morley, Yvonne Cypher and Basim Khattab (PwC) explain the importance of businesses retaining documentation of commercial decision making as HMRC increasingly focuses on areas of international tax risk.

Damiano Sogaro and Gideon Sanitt (Macfarlanes) review recent litigation on the tribunal's role in determining domicile issues when considering challenges to an enquiry or to information notices.

Marika Lemos (Devereux Chambers) and James Austen (Collyer Bristow) assess the impact of an important Upper Tribunal decision.
Barrister Oliver Marre (5 Stone Buildings) reflects on the use of judicial review as a key safeguard on HMRC’s powers.
HMRC’s attempts to reverse the limitations imposed by the Court of Appeal backfired, as Ben Elliott (Pump Court Tax Chambers) explains.
What rights do those indirectly affected by tax disputes have if they disagree with the outcome? 
In May, the EU General Court delivered two judgments on fiscal state aid. George Peretz QC (Monckton Chambers) explains why they still matter in the UK in light of the UK’s proposed state aid regime.
The ‘revenue rule’ is a longstanding legal principle that the courts of one country will not enforce the tax laws of another country. It was recently tested in the High Court, as David Corker and Claire Cross (Corker Binning) report.
With the recent decisions in Hurstwood Properties and Bostan Khan, the courts are again grappling with exactly what it means to construe statutory provisions purposively, writes Dominic Stuttaford (Norton Rose Fulbright).
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