European Tax

Can a taxpayer rely on a treaty exemption on the disposal of a shareholding if the gain is not taxed in the taxpayer’s state of...

In a decision of significance for the secondary debt market, the Court of Appeal in Burlington has unanimously dismissed HMRC’s appeal....

When is capital expenditure "on the provision of plant” for the purposes of section 11 Capital Allowances Act 2001? This was the question...

There are many places in the UK tax legislation where deeming provisions are employed in order to apply the tax rules to particular...

The Supreme Court in Hotel La Tour has unanimously rejected the taxpayer’s appeal and determined that the input tax on deal fees...

The November 2025 budget is here at last. During the months of speculation in the run-up to the big day, two possible futures emerged: a...

Amidst the broader UK stamp taxes on shares modernisation efforts (discussed here and here), today in her Autumn Budget 2025, the...

So far, our blog post series on tax disputes in the UK has focussed generally on enquiries and appeals processes. Here, we focus on...

With HMRC statistics showing that HMRC was successful (at least in part) in 93% of First-tier Tribunal (FTT) tax cases in 2024/25, many...

The First-tier Tribunal (FTT) is the first stage of the court process for appealing, for instance, a corporation tax assessment. The...

Previous posts in our series on tax disputes in the UK considered how an HMRC enquiry is likely to proceed and be concluded. In this and...

If a tax treaty is engaged, it may be possible to ask HMRC to consider how that tax treaty will interact with the enquiry – that is what...

HMRC enquiries can be a frustrating process. There is no time limit for HMRC to complete an enquiry and enquires can continue for many...

Imagine a scenario where two companies are in a VAT group and one supplies investment management services to the other. Consideration for...

HMRC cannot demand disclosure of documents that are subject to legal professional privilege. However, it is not uncommon for HMRC to ask...

A notice of enquiry will almost always be accompanied by a request for information. In the previous blog of this series on tax disputes...