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The High Court has dismissed a claim by the Danish tax authorities (against more than 100 defendants) that it was wrongly induced to refund more than £1bn of tax. It did so based on the established principle that English courts will not enforce foreign revenue laws. Unless reversed, the decision will cast doubt on the ability of other tax authorities to proceed with cum/ex fraud claims in the High Court. Read more
In the latest round of litigation in HMRC's bid to avoid a settlement agreement with members of the GE group of companies, the Court of Appeal has refused HMRC permission to amend their case to seek the equitable rescission of the settlement agreement on the ground of fraudulent misrepresentation. Although the decision offers some comfort to the taxpayers concerned, it serves as a reminder that taxpayers should approach settlement discussions with HMRC with care. Read more
In this article, we consider a recent case which is of considerable interest to tax practitioners given its focus on the income tax consequences of correcting mistakes in bilateral contracts. Read more
In Mackay v Wesley [2020] EWHC 1215 (Ch), the Claimant, who was instructed by her father to become a trustee of a family trust as part of a tax scheme, failed to obtain from the High Court (1) an order rescinding her appointment as trustee and/or (2) a declaration that she never became a trustee. Read more
In Littlewoods Ltd and others v HMRC [2017] UKSC 17, the Supreme Court delivered a controversial decision in favour of HMRC, resulting in the failure of the taxpayer's claim for compound interest of £1.2 billion.Read more
