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Original Difficulties
HMRC’s concern that taxpayers should not obtain fiscal advantages which do not reflect the real economic result of…
A Long Way from home?
During all the recent furore over the fiscal affairs of the Chancellor and his wife, what has most…
Unappealing odds
The risks of tax litigation are stacked against the taxpayer. The rewards of success in fiscal litigation must…
Best private client tax practice
We are proud to announce that we have been shortlisted in the Taxation Awards in the category of…
A heart-warming tale
The valuation of transactions for fiscal purposes can be a peculiar world in which the taxpayer is often…
Constructive confinement
The decision in Embiricos takes a puzzlingly restricted view of the scope of partial closure notices.
Wise in their own conceit
When a statutory test of residence was proposed by the Government, the professional bodies most concerned with taxation…
Unconvincing promotions
Many years after most responsible advisers abandoned recommending tax avoidance schemes to their clients because they were no…
Residence of convenience
Even experienced tax advisers often assume that the summaries of fiscal law in HMRC’s Manuals have been arrived…
Parallel Worlds
Cases often reveal the Judiciary’s assumptions about the society in which we live. Those assumptions are often startlingly…
Artificial Tax Planning
Tax planning normally involves planning not to pay tax, or at least to reduce the amount of tax…
Valuable Expertise?
Valuation, it is often said, is not an art but a science.  A recent case suggests that it…
Power without Responsibility
Those who deal regularly with matters of domicile and residence know that HMRC routinely requests large shopping lists…
Time’s Fools
We have always enjoyed explaining to our clients why the UK’s fiscal year ends on 5th April.  A…
First Tier Union
It is for the Court to determine what is the content of the law of the country in…