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RPC | European Union | 8 Mar 2013

ECJ ruling in Grattan Plc v Revenue and Customs Commissioners 2012 All ER (D) 246 (Dec)

The Court of Justice of the European ('ECJ') has recently confirmed the opinion of the Advocate General in Grattan Plc v HMRC. The case concerned the


RPC | United Kingdom | 20 Feb 2013

Late expectations taxpayers succeed in their application to appeal out of time

The 30 day time limit, contained in section 31A Taxes Management Act 1970 ('TMA 1970'), for giving notice of appeal against an amendment of a


RPC | United Kingdom | 1 Feb 2013

Taxpayer misled by HMRC amidst settlement confusion

It is normally very clear to both parties when a tax dispute has been settled by way of agreement, but this is not always the case, especially when


RPC | United Kingdom | 21 Dec 2012

Green light for TNT's judicial review

Unperturbed by the High Court's initial dismissal of their attempt to judicially review HMRC's VAT exemption for postal access services provided by Royal Mail, TNT requested an oral hearing and have now been granted permission to challenge the VAT exemption by way of judicial review (see R (on the application of TNT Post UK Limited) v Commissioners for HM Revenue & Customs (defendant) and Royal Mail Group Limited (Interested Party) 2012 EWHC 3380 (Admin)).


RPC | United Kingdom | 9 Nov 2012

Taxpayer wins on purposive interpretation

In recent years, it is usually HMRC pressing the courts to identify the purpose of the legislation and to reject a narrow interpretation of the legislation.


RPC | United Kingdom | 18 Oct 2012

Tax win puts McLaren in pole position!

The glamorous world of Formula One does not often collide with the more cerebral realm of the First-tier Tribunal (‘FTT’), but this is precisely what happened in McLaren Racing Limited v HMRC 2012 UKFTT 601 (TC).


RPC | United Kingdom | 17 Sep 2012

Costs against HMRC the importance of getting your arguments right

There have been a number of cases addressing the powers of the First-tier Tribunal (‘FTT’) in respect of the awarding of costs since the FTT was established in 2009.


RPC | United Kingdom, European Union | 15 Aug 2012

Significant watering down of anti-avoidance legislation

On 30th July 2012 HMRC released a consultation document entitled “Reform of two anti-avoidance provisions: (i) the attribution of gains to members of closely controlled non-resident companies, and (ii) the transfer of assets abroad.”


RPC | United Kingdom | 24 Jul 2012

Bringing it all back home tribunal rejects HMRC’s arguments on remittances

In Pflum v HMRC 2012 UKFTT 365 (TC), the First-tier Tribunal has found in favour of the taxpayer in a recent appeal concerning taxation of remittances from overseas under section 26 of the Income Tax (Earnings and Pensions) Act 2003.


RPC | United Kingdom | 2 Jul 2012

Behind closed doors: HMRC denied access to Charman papers

In the recent case of HMRC v Charman 2012 EWHC 1448 (Fam), HMRC failed in their bid to obtain documents produced in a high profile divorce case.

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