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The Court of Appeal considers proportionality in judicial review
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 23 2016

The Court of Appeal has held in J P Whitter (Waterwell Engineers) Limited v The Commissioners for Her Majesty's Revenue and Customs 2016 EWCA


Tax deductibility of corporate interest expense
  • Herbert Smith Freehills LLP
  • OECD, United Kingdom
  • July 18 2016

On 12 May 2016, HM Treasury and HM Revenue & Customs (HMRC) published their second consultation document on the detailed policy design and


"Extreme shopping": HMRC legislation to counter treaty shopping: thoroughly draconian
  • Herbert Smith Freehills LLP
  • United Kingdom
  • August 5 2011

On 1 August, just before the summer break, HM Revenue & Customs (HMRC) published a "Technical Note" and draft legislation (together, the "Note") entitled "Tax Treaties Anti-avoidance"


Supreme Court rules in judicial review on scope of duty of confidentiality owed by public bodies
  • Herbert Smith Freehills LLP
  • United Kingdom
  • November 11 2016

The Supreme Court has granted judicial review of a decision by Her Majesty's Revenue and Customs ("HMRC") to reveal confidential taxpayer information


Resolving disputes with HMRC
  • Herbert Smith Freehills LLP
  • United Kingdom
  • July 20 2015

This is the eighth in our series of ADR practical guides, designed to provide clients with essential practical guidance on various processes falling


New UK criminal offences of failure to prevent facilitation of tax evasion
  • Herbert Smith Freehills LLP
  • United Kingdom
  • December 5 2016

In our October 2016 briefing, we reported on the publication of the Criminal Finances Bill 201617. The Bill introduces a range of new measures to


Supreme Court applies purposive construction to defeat bank bonus tax avoidance schemes
  • Herbert Smith Freehills LLP
  • United Kingdom
  • March 10 2016

The decision of the Supreme Court in two appeals concerning the effectiveness of bonus arrangements involving allocations of restricted securities to


HM Revenue & Customs (HMRC) enquiry windowslimitation periods
  • Herbert Smith Freehills LLP
  • United Kingdom
  • April 29 2010

From 1 April 2010, changes introduced by Schedule 39 Finance Act 2008 will take effect and reduce the period within which HMRC can bring an assessment to four years from the end of the accounting period in the case of innocent errors, six years for careless errors and 20 years for deliberate mistakes


HMRC v Philips Electronics UK Limited
  • Herbert Smith Freehills LLP
  • European Union, United Kingdom
  • September 7 2012

On 6 September 2012 the CJEU delivered a clear ruling in favour of Philips, confirming that the UK provisions which prevent losses of UK branches of non-UK resident companies from being surrendered for group relief (section 107 CTA 2010 condition C, formerly section 403D(1)(c) ICTA 1988) constitute an unjustified restriction of the freedom of establishment under EU law


Appeals against conclusions set out in a closure notice HMRC v Tower MCashback (decision of the Court of Appeal)
  • Herbert Smith Freehills LLP
  • United Kingdom
  • February 5 2010

On an appeal by a taxpayer against the conclusions set out in a closure notice, HMRC may only raise and rely on grounds in support of its conclusions which relate to the subject matter of the enquiry (as determined by the First-tier Tribunal