The doctrine of legitimate expectation arises in UK disputes where HM Revenue & Customs (HMRC) has reversed its position on a ruling issued to a taxpayer to the detriment of the taxpayer. At a seminar hosted by PwC Legal in London on Monday, Sam Grodzinski QC, of Blackstone Chambers, highlighted the issue and explained how taxpayers should assess when a legitimate expectation argument will succeed.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
Rolling out the global minimum tax has increased complexity, according to Baker McKenzie; in other news, Donald Trump has announced a 25% tariff on countries doing business with Iran