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

We asked trust companies questions about the most significant risk and compliance issues they face. This blogpost, and accompanying podcast, consider the tax issues identified by respondents as most pressing. Read more

Where a loss of tax has been brought about deliberately by a taxpayer, the time limit for HMRC to raise a discovery assessment is increased from 4 years to 20 years.  In The Commissioners for HMRC v Raymond Tooth, the Court of Appeal held that for an inaccuracy to be "deliberate", there need not be any culpable conduct attributable to the taxpayer in question. Read more

In this webinar, we focus on developments relating to cross-border transparency and new penal regimes. Read more

In this briefing, we consider the background to the introduction of the offences, the components of the offences, the "reasonable prevention procedures" defence, and enforcement mechanics. Read more