“Tax Investigations and Disputes notes” is the Herbert Smith Freehills blog where clients will find the latest developments on Tax Investigations and Disputes.
Articles: 1-10 of 12
Royal Bank of Canada: A common sense approach to tax treaty interpretation
Canada, United Kingdom - June 30 2023 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 interpretation of the…
Third party access to pleadings in the FTT
United Kingdom - March 10 2022 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
United Kingdom - March 8 2022 Judgment was handed down by Zacaroli J today in McClean & Others v Thornhill [2022] EWHC 457 (Ch). The decision will be of interest to professional…
No input VAT deduction for VAT not in fact charged
European Union, United Kingdom - January 20 2022 The Court of Justice of the European Union (“CJEU”) has held that, where a contract for services provides for…
Estoppel by convention and notices of enquiry
United Kingdom - August 2 2021 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
United Kingdom - July 20 2021 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
United Kingdom - July 9 2021 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…
What is “reasonable detail” when notifying a tax claim under an SPA?
United Kingdom - May 18 2021 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…
Danish WHT fraud claim dismissed
Denmark, European Union, United Kingdom - May 6 2021 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
United Kingdom - April 23 2021 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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