Disputes with HMRC: appeals

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Practice notes
SDLT—deeds of rectificationStamp duty land tax (SDLT) ceased to apply to any land transaction involving any interests in or over land in Scotland from...
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19th May
Practice notes
VAT—triangulationIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following...
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Produced in partnership with John Fuszard of Sagars Accountants Ltd 19th May
Practice notes
VAT treatment of damages and compensation paymentsFORTHCOMING CHANGE: HMRC is in the process of revising Revenue and Customs Brief 12 (2020) on the...
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19th May
Practice notes
Key tax consequences of an insolvent liquidationThis Practice Note outlines:•the main corporation tax consequences when a UK incorporated company...
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Produced in partnership with Julia Fox of Deloitte LLP and Anthony Davis 19th May
Practice notes
EIS—deferred gain becomes chargeable to CGTCoronavirus (COVID-19): In response to the coronavirus (COVID-19) pandemic, the government introduced a...
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19th May
Practice notes
Property holding structures—SDLT and VAT treatment of a Jersey Property Unit Trust (JPUT)IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the...
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19th May
Practice notes
VAT on composite suppliesSingle composite supplies vs multiple suppliesWhere a supply comprises a number of different elements with varying VAT...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 19th May
Practice notes
Commercial service charges—VAT implicationsThis Practice Note is about the VAT treatment of non-residential service charges. General positionService...
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Produced in partnership with Martin Scammell 19th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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19th May
Practice notes
FATCA in the UK—the UK:US Intergovernmental Agreement: an outlineIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 19th May
Practice notes
Tax considerations on a loan agreement—the tax gross up clauseIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit...
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Produced in partnership with Eloise Walker of Pinsent Masons 19th May
Practice notes
Loan capital exemption from stamp dutyDebt which:•qualifies as loan capital (whether it is short or long-term debt), and•satisfies further conditions...
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19th May
Q&As
Corporate redomiciliation—can a non-UK company redomicile into the UK?It is possible for a non-UK incorporated company to redomicile to the UK....
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19th May
Practice notes
Why have a tax covenant?It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a...
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19th May
Practice notes
R&D capital allowancesFORTHCOMING CHANGE: At Spring Budget 2021, the government announced a wide-ranging review of research and development (R&D)...
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Produced in partnership with Anne Fairpo of Temple Tax Chambers 19th May
Practice notes
Transfer of a trade under common ownershipSometimes the restructuring of a business will involve a company transferring an existing trade to a...
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19th May

Most recent Disputes with HMRC: appeals content

Q&As
What is the deadline for appealing an FTT decision?In order to make an appeal, a taxpayer must first apply for permission to appeal (PTA). The PTA...
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1st Aug
Q&As
Is there a time limit for asking for a review of an HMRC decision?In respect of an HMRC decision relating to direct tax, a taxpayer normally has 30...
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1st Aug
Q&As
Is a First-tier Tax Tribunal (FTT) decision binding on HMRC?Although a First-tier Tax Tribunal (FTT) decision is binding on the parties to the...
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1st Aug
Q&As
What is the meaning of ‘possession or control’ in the context of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009, SI 2009/273,...
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1st Aug
Practice notes
Convention rightsThe European Convention on Human Rights (ECHR) was adopted by the Council of Europe in 1950. The ECHR sets out the rights and...
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Produced in partnership with Alexander Campbell of Field Court Chambers 1st Aug
Q&As
Where a discovery amendment has been made to the tax return of a dissolved, trading limited liability partnership under section 30B of the Taxes...
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Produced in partnership with Denis Edwards of Normanton Chambers 1st Aug
Practice notes
An introduction to the Human Rights Act 1998Convention rightsThe Human Rights Act 1998 (HRA 1998) came into force in October 2000 and aims to give...
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Produced in partnership with Dr. Alex Williams of Cornerstone Barristers 31st Jul
Practice notes
Dealing with a human rights challengeThe Human Rights Act 1998 (HRA 1998) imposes a duty on all public authorities in the UK to act in a manner that...
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Produced in partnership with Eric Metcalfe of Monckton Chambers 31st Jul
Practice notes
Appealing beyond the First-tier Tax TribunalFORTHCOMING CHANGE: The Ministry of Justice is consulting on proposals to amend arrangements for obtaining...
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Produced in partnership with Anne Redston 31st Jul
Practice notes
Should I appeal to the tax tribunal?This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to...
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Produced in partnership with Anne Redston 31st Jul
Practice notes
Privilege in tax casesThis Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the...
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Produced in partnership with Anne Redston 31st Jul
Practice notes
VAT on costsThis Practice Note explains the special provisions that pertain to VAT in relation to costs that are the subject of either summary or...
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31st Jul
Practice notes
Coronavirus (COVID-19) and tax—impact on tax appeals and tax tribunalsAppeals and applications to the First-tier Tribunal and Upper Tribunal are both...
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31st Jul
Practice notes
What happens at a tax tribunal hearing?This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised...
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Produced in partnership with Anne Redston 31st Jul
Practice notes
Electronic bundles in civil proceedingsEffective preparation of bundles is an essential element of a smooth, orderly hearing and something which...
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Produced in partnership with Quinn Emanuel Urquhart & Sullivan UK LLP 31st Jul
Practice notes
Preparing for a tax tribunal caseThis Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to...
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Produced in partnership with Anne Redston 31st Jul
Practice notes
HMRC review of a decisionThis Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for...
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Produced in partnership with Anne Redston 31st Jul
Practice notes
Appealing an HMRC decisionCoronavirus (COVID-19) impact on tribunals: For information on the coronavirus implications for appeals to, and hearings at,...
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Produced in partnership with Anne Redston 31st Jul
Practice notes
Appeals—options after the First-tier Tax Tribunal decisionThis Practice Note has been written by Anne Redston, Barrister. It is her personal view; she...
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Produced in partnership with Anne Redston 30th Jul

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