Taxpayers often learn just as much from defeats in the courtroom as from their victories.
While decisions against the revenue authorities vindicate the positions companies take over their planning or structuring, losses help taxpayers to identify areas of greatest future risk and where the authorities are most likely to focus their attention.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap