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Royal Bank of Canada: A common sense approach to tax treaty interpretation
Introduction In Royal Bank of Canada v HMRC [2023] EWCA Civ 695, the Court of Appeal upheld the taxpayer's appeal in a case relating to the …
Third party access to pleadings in the FTT
In Cider of Sweden Ltd v HMRC (Ernst & Young LLP (Third Party)) [2022] UKFTT 76 (TC), the First-tier Tribunal ("FTT") has issued a significant, but …
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 …
No input VAT deduction for VAT not in fact charged
In Zipvit Ltd v HMRC (Case C-156/20), the Court of Justice of the European Union ("CJEU") has held that, where a contract for services provides for VAT …
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 …
Kandore: information notices and the limits of open justice
HMRC's powers under Schedule 36 Finance Act 2008 ("Schedule 36") to obtain information relating to a taxpayer's affairs from a third party are …
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 …
What is "reasonable detail" when notifying a tax claim under an SPA?
In Dodika Limited (and others) v United Luck Group Holdings Limited [2021] EWCA Civ 638, the Court of Appeal held that the Defendant had complied with …
Danish WHT fraud claim dismissed
The High Court in Skatteforvaltningen v Solo Capital Partners LLP & Ors [2021] EWHC 974 (Comm) ("Solo Capital") has dismissed claims brought by the …
HMRC's ability to argue fraudulent misrep hindered
In IGE USA Investments Limited v HMRC [2021] EWCA Civ 534, the Court of Appeal overturned part of an interlocutory decision of the High Court dealing …
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