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Not as far as HMRC would appear to want it to. The First-tier Tribunal’s procedural decision in Motorplus is another example of somewhat...
The spectre of Albert Venn Dicey, the greatest of Victorian constitutionalists, looms large at the feast. In Skatteforvaltningen v Solo...
Multinational companies increasingly face situations where two or more countries seek to tax the same profits. Recently enacted and...
As mentioned in my earlier post, the UK’s proposed “Financial Institution Notices” (FINs) would give HMRC easier and quicker access to...
Looking at the CJEU decision in Luxembourg v B in the context of the UK's proposed new Financial Institution Notice (which would allow...
The UK government has announced plans to introduce a “Financial Institution Notice” which would allow HMRC to request information from...
Today is the first OECD Tax Certainty Day. We have asked some of our authors for their thoughts on the topic. One of my fellow panellists...
In the past, many tax disputes were run as technical debates, where the parties (largely) agreed the facts, the court had little...