Miscellaneous

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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.
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…
Time’s Fools
We have always enjoyed explaining to our clients why the UK’s fiscal year ends on 5th April.  A…
A Happy 21st for the Tax Cartel
Imagine that the major food manufacturers combined to place a minimum price on food so as to restrict…
First Tier Union
It is for the Court to determine what is the content of the law of the country in…
Your money or your life
HMRC’s overwhelming resources often allows it to collect tax which is not due.  A taxpayer assessed on a…
Paradise regained
As we adapt to the restoration of our sovereignty, the opportunities and minor irritations resulting from Brexit continue…
Involuntary Audience
The case of N v. HMRC (CHB) [2021] was an interesting non-tax case of relevance to tax practitioners. …
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