Shiv Mahalingham (Duff & Phelps) examines recent developments affecting transfer pricing.
Sometimes the tribunal will adopt an impressionistic approach to interpreting the legislation, writes Stefano Mariani.
The High Court has rejected a judicial review application challenging the legality of accelerated payment notices, as well as their compatibility with human rights (Nigel Rowe and others v HMRC [2015] EWHC 2293).
The Ministry of Justice is consulting on proposals to introduce fees for taxpayers who take their cases to the First-tier or Upper Tribunal as part of a wider set of proposals to introduce and or increase charges for courts and tribunals.
The Upper Tribunal has published its updated list of pending and past cases to 24 July 2015 which confirms that HMRC is appealing against the decision in Leekes Ltd on loss streaming. See www.bit.ly/1Bq8Zdc.
As previously reported in Tax Journal, the Welsh Assembly’s Finance Committee published the Tax Collection and Management (Wales) Bill in draft to establish the Welsh Revenue Authority, and put in place the legal framework for administration of the proposed new devolved taxes, land trans
HMRC has published the Tax Assurance Commissioner’s annual report 2014/15, which outlines HMRC’s performance in resolving disputes with taxpayers for the year ended March 2015. It is the third report of its type.