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TAX POLICY ADMINISTRATION


Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case

Andrew Roycroft (Norton Rose Fulbright) reviews the decision in the case of Bupa Insurance, which serves as a reminder that a tax avoidance purpose is, of itself, not sufficient for HMRC to deny a taxpayer its intended tax outcome

The forthcoming Scottish referendum will be fought on many issues but taxation, and in particular North Sea taxation, is one of the most important, as David Smith reports

Go directly to jail; do not pass ‘go’; do not collect £200. Is HMRC’s approach  getting out of hand, asks Peter Vaines, partner, Squire Patton Boggs

Section 54 agreement and duress

Notice for security

Late appeal and reasonable excuse

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.

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