Disputes with HMRC: appeals

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Practice notes
Unilateral relief, like double tax relief, aims to relieve double taxation. Subject to certain conditions being satisfied and specific limits,...
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9th Nov
Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Brexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
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 sale of all the shares...
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9th Nov
Practice notes
The reasons why a company might carry out a demerger, and the different ways in which a demerger may be structured, are described in Practice Notes:...
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Produced in partnership with Zoe Feller of Bird & Bird 12th Jan
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Practice notes
The international movement of capital rules should be considered whenever:•any non-UK tax resident subsidiary (referred to in this note as a foreign...
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Disputes with HMRC: appeals content

Precedents
Filed on behalf of the [insert party eg [Claimant OR Appellant] or [Defendant OR Respondents]]Number of witness statement: [insert eg first]Date:...
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12th Apr
Practice notes
Appeals and applications to the First-tier Tribunal and Upper Tribunal are both significantly affected by the coronavirus (COVID-19) pandemic. This...
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9th Apr
Practice notes
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
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Produced in partnership with Anne Redston 9th Apr
Practice notes
The Human Rights Act 1998 (HRA 1998) imposes a duty on all public authorities in the UK to act in a manner that is compatible with rights under the...
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Produced in partnership with Eric Metcalfe of Monckton Chambers 9th Apr
Practice notes
The European Convention on Human Rights (ECHR) was adopted by the Council of Europe in 1950. The ECHR sets out the rights and freedoms which the...
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Produced in partnership with Alexander Campbell of Field Court Chambers 9th Apr
Practice notes
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
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Produced in partnership with Anne Redston 2nd Apr
Practice notes
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
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Produced in partnership with Anne Redston 26th Mar
Practice notes
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
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Produced in partnership with Anne Redston 24th Mar
Practice notes
Effective preparation of bundles is an essential element of a smooth, orderly hearing and something which practitioners should keep in clear focus as...
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Produced in partnership with Quinn Emanuel Urquhart & Sullivan UK LLP 23rd Mar
Practice notes
This Practice Note explains the special provisions that pertain to VAT in relation to costs that are the subject of either summary or detailed...
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20th Mar
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Dr. Alex Williams of Cornerstone Barristers 10th Mar
Practice notes
FORTHCOMING CHANGE: The Ministry of Justice is consulting on proposals to amend arrangements for obtaining permission to appeal from the Upper...
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Produced in partnership with Anne Redston 1st Mar
Practice notes
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
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Produced in partnership with Anne Redston 25th Feb
Practice notes
Coronavirus (COVID-19) impact on tribunals: For information on the coronavirus implications for appeals to, and hearings at, the tax tribunals, see...
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Produced in partnership with Anne Redston 25th Feb
Practice notes
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
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Produced in partnership with Anne Redston 25th Feb
Practice notes
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
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Produced in partnership with Anne Redston 23rd Feb
Practice notes
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
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Produced in partnership with Anne Redston 23rd Feb
Precedents
TC/[insert year]/[insert case number]In the first tier tribunal(Tax chamber)Between:[Name of appellant]AppellantandThe commissioners for her majesty’s...
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17th Feb
Precedents
TC/[insert year]/[insert case number]In the first tier tribunal(Tax chamber)Between:[Name of appellant]AppellantandThe commissioners for her majesty’s...
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17th Feb

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