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
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
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
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)).
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.
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).
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.
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.”
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.
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.