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High Court finds no duty owed to investors by barrister advising scheme promoter
Judgment was handed down by Zacaroli J today in McClean & Others v Thornhill [2022] EWHC 457 (Ch). The decision will be of interest to …
When can a partial closure notice be required?
In Embiricos v HMRC [2022] EWCA Civ 3, the Court of Appeal confirmed that where HMRC's conclusion in respect of a matter enquired into has computational …
Estoppel by convention and notices of enquiry
In Tinkler v HMRC [2021] UKSC 39, the Supreme Court held that a taxpayer (Mr Tinkler) was prevented (estopped by convention) from challenging the …
Supreme Court provides guidance on Follower Notices
In R (on the application of Haworth) v HMRC [2021] UKSC 25, the Supreme Court has upheld the Court of Appeal's decision quashing a follower notice issued …
Supreme Court rules on what is "deliberate"
The Supreme Court has dismissed the Revenue's appeal in HMRC v Tooth [2021] UKSC 17, a case concerning whether a "discovery assessment" was validly made …
Mutual mistake and rectification: lessons to be learned from MV Promotions v TMG
A number of important points emerge from the recent decision in MV Promotions Limited and Micheal Vaughan v Telegraph Media Group Limited and HMRC [2020] …
High Court offers sympathy but no remedy to trustee facing unexpected tax bill
In Mackay v Wesley [2020] EWHC 1215 (Ch), the Claimant, who was instructed by her father to become a trustee of a family trust as …
Tax Treaty Interpretation: The Limits of Fiction
In Fowler v HMRC [2020] UKSC 22, the Supreme Court determined that a statutory fiction created by a deeming provision of UK tax law did not …
HSF Trust Companies Survey - Tax Insights
We asked trust companies questions about the most significant risk and compliance issues they face. The survey mapped which specific tax compliance …
Rapid resolution of domicile disputes: be careful what you wish for
In Henkes v HMRC [2020] UKFTT 7645 (“Henkes”), the First-tier (Tax) Tribunal (“the Tribunal”) held that (a) it could (and would) …
HMRC guidance on statutory residence test and COVID-19
HMRC has updated its guidance on the Statutory Residence Test (“SRT”) to extend the exceptional circumstances disregard to cover COVID-19. When …
Lloyd-Webber v HMRC: Music to off-plan investors' ears?
In a decision that will be a welcome source of comfort for investors in potentially risky off-plan property developments, the First-tier Tribunal (Tax) …
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