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Trustee self-dealing in the light of the E&F Settlements cases

United Kingdom - February 18 2021 Trustees, as with other types of fiduciary, must not place themselves in a position where their personal interests conflict, or may potentially…

Thomas Schlee.

Corporate residence - the Court of Appeal decision in Development Securities

United Kingdom - January 11 2021 The Court of Appeal has overturned the taxpayer’s successful appeal to the Upper Tribunal in the case of Development Securities v HMRC, a case on the…

Paul Hardwick.

The tax avoidance anomaly - transfer of assets abroad

United Kingdom - July 7 2020 The tax avoidance anomaly - transfer of assets abroad We reported recently on the decision of the Upper Tribunal in Fisher v HMRC. An English c…

Jennifer Smithson, Mark Hunter.

Relying on HMRC’s guidance - is it safe to do so?

United Kingdom - January 27 2020 A recent Court of Appeal judgment has considered the circumstances in which HMRC’s guidance may give taxpayers a legitimate expectation that is…

Gideon Sanitt, Pippa Goodfellow.

Corporate residence - new developments

United Kingdom - June 19 2019 The Upper Tribunal has overturned HMRC’s first instance victory in the case of Development Securities v HMRC, a case on the tax residence of…

Paul Hardwick, Robin Vos.