Discovery assessments and related appeals
Adam Craggs (RPC) takes a look at the First-tier Tribunal decision in Rotberg, and the extent of the tribunal’s jurisdiction
Rupert Shiers (Hogan Lovells) considers the Court of Appeal judgment in Lloyds TSB Equipment Leasing (No. 1) and HMRC’s new-found enthusiasm for applying main purpose tests.
HMRC is consulting on the enactment of ESC D33. Paul Howard (Gabelle) reports.
HMRC has restricted the availability of the Liechtenstein disclosure facility (LDF). The restrictions are subject to three key exclusions; these are not as clear cut as one might think, writes Simon Airey, head of tax investigations, DLA Piper
The CIOT has welcomed the passing of the Revenue Scotland and Tax Powers Bill by the Scottish Parliament. The Bill means that Scotland now has the legal framework to operate its own tax authority for devolved taxes.
Late withdrawal of case by HMRC
Avoidance involving the transfer of assets to Gibraltar
Reasonable excuse