Fresh Perspectives

On this page

RPC Tax Take brings current information and comment to busy practitioners, featuring the latest news and developments in UK tax law. Click on 'Podcasts' above for our Taxing Matters podcasts.

Untinted 3 wide
Blog

Siddiqui - No proper ground for setting aside summons in private prosecution

Topic: Tax Take 21.07.2021 Read more
Blog

Golamreza – HMRC assessments and the burden of proof

Topic: Tax Take 14.07.2021 Read more
Untinted 3
Blog

Perring – Burden of proof for establishing that documents are 'reasonably required' in taxpayer information notice appeal is on HMRC

Topic: Tax Take 07.07.2021 Read more
Blog

Aozora - Unilateral credit for US withholding tax allowed even where no treaty relief available

Topic: Tax Take 30.06.2021 Read more
Untinted 3
Blog

Rediscovering ADR

Topic: Tax Take 23.06.2021 Read more
Abstract building
Blog

Tooth – Supreme Court rejects the concept of 'staleness' and confirms the meaning of 'deliberate'

Topic: Tax Take 16.06.2021 Read more
Untinted 5 wide
Blog

Hargreaves - Burden of proof on HMRC in taxpayer information notice appeals

Topic: Tax Take 09.06.2021 Read more
Exterior and sunset
Blog

Daarasp – Loss claims denied as closure notices were valid

Topic: Tax Take

Published by Alexis Armitage, Associate

In Daarasp LLP & Betex LLP v HMRC [2021] UKUT 0087, the Upper Tribunal (UT) upheld the First-tier Tribunal's (FTT) decision and dismissed the taxpayers' claims for losses as the conclusions in HMRC's closure notices were not inconsistent with the losses being reduced to zero in the taxpayers' returns.

02.06.2021 Read more
Blog

Comtek – Counteraction steps taken after Follower Notice deadline can reduce penalty

Topic: Tax Take 26.05.2021 Read more
Exterior and sunset
Blog

Euromoney – Tribunal considers 'main purpose' test

Topic: Tax Take

Published by Rebekka Sandwell, Associate

In Euromoney Institutional Investor PLC v HMRC [2021] UKFTT 0061 (TC), the First-tier Tribunal (FTT) upheld the appellant's appeal, finding that the avoidance of liability to tax was a purpose, but not the main purpose, or one of the main purposes, of the relevant arrangements, for the purposes of section 137(1), Taxation of Chargeable Gains Act 1992 (TCGA).

19.05.2021 Read more