12 Feb, 2024 Fake cases and real consequences: the risks of relying on AI in litigation By Jackelyn West Oliver Jeffcott Blaise Kingan The recent case of Harber v HMRC in the First-tier Tax Tribunal (the FTT) has resulted in considerably more commentary over the last...
07 Dec, 2023 Play your cards right: betting company secures DPA in relation to historic bribery By Helen Harvey Victoria Braid What started off in 2019 as an HMRC investigation into the activities of Entain Plc’s (Entain) former Turkish-facing online betting and...
15 Nov, 2023 Supreme Court allows Danish tax authority to litigate in English courts By Edward Reed Alice Mason Victoria Braid The Supreme Court has recently ruled that a claim brought by the Danish Customs and Tax Administration, Skatteforvaltningen (SKAT), is...
25 Jul, 2023 Crime and (deferred) Punishment: What Entain tells us about the role of HMRC and prosecuting bodies By Helen Harvey Victoria Braid In May 2023, FTSE 100 company Entain Plc (Entain) announced that it anticipated receiving a “substantial” financial penalty following an...
21 Dec, 2022 Embiricos v HMRC – a second bite of the procedural cherry By Luke Silverman Earlier this year, in Embiricos v HMRC [2022] EWCA Civ 3, the Court of Appeal held that HMRC could not issue a partial closure notice to...
24 Nov, 2022 Expenses of management: what the judgment in Centrica means for the deductibility of deal fees By Lawrence Parkin The Court of Appeal's judgment in HMRC v Centrica Overseas Holdings Limited denies a corporation tax deduction for a range of sell-side...
09 Jun, 2022 A more appealing position: changes to applying for permission to appeal By Sophie Rhind As a successful party in litigation, content with the outcome of a decision, you would not expect to have to give immediate consideration...
26 May, 2022 Can't PAYE? We'll take it away! HMRC's discretion to disapply PAYE By Jackelyn West Jamie Golding In the recent decision of Hoey v HMRC EWCA Civ 656 (Hoey), the Court of Appeal confirmed that HMRC has a very wide discretion to disapply...
25 Mar, 2022 Spring Statement 2022: key announcements for tax compliance By Jackelyn West Sophie Rhind It comes as no surprise that the Spring Statement 2022 is focused on the cost of living crisis exacerbated by the war in Ukraine. As well...
01 Mar, 2022 Supreme Court refuses permission in Development Securities By Jackelyn West A year ago we wrote about the Court of Appeal’s decision in Revenue and Customs Commissioners v Development Securities plc and others...
14 Feb, 2022 The big freeze on crypto-assets: HMRC seizes its first ever NFT By James Reid HM Revenue & Customs (HMRC) has announced its first ever seizure of Non-Fungible Tokens (NFTs) as part of a £1.4m VAT fraud...
14 Dec, 2021 No decision? No problem: challenging tax in the High Court By Jackelyn West In most circumstances, a decision issued by HMRC may be appealed to the First-tier Tax Tribunal or, if the dispute raises public law...
10 Dec, 2021 Mind the (interpretation) gap: Governmental attitudes towards "incorrect" legal interpretations By Gideon Sanitt Victoria Braid The Times has recently reported that the Government is seeking to limit the power of the courts to overrule decisions made by ministers...
02 Dec, 2021 An unappealing position: lack of clarity in Dunsby v HMRC on when permission to appeal is required By Sophie Rhind The recent Upper Tribunal (UT) case of Dunsby v HMRC [2021] UKUT 0289 (TCC) has raised again the issues that parties face when appealing...
16 Nov, 2021 Policy in practice episode 3: What next for judicial review? By David Gauke Gideon Sanitt Jonathan Pratt In episode 3 of our policy in practice podcast David Gauke and Gideon Sanitt chat with Jonathan Pratt about the Government's proposals...
08 Nov, 2021 HMRC's focus on CJRS compliance grows now that support has come to an end By Jackelyn West 15 months ago, we wrote about HMRC’s announced plans to start recovery action of overpaid grants under the Coronavirus Job Retention...