Investors in a series of film finance tax schemes sued the tax QC who had produced written opinions for the scheme promoter, which were then shared with prospective investors. The Court rejected the investors' claims, on the basis that the QC owed them no duty of care in preparing the opinions, and that even if he had owed them a duty, the views he expressed in the opinions were consistent with those of a reasonable QC. Read more

In Zipvit Ltd v HMRC, the CJEU has held that, where a contract for services provides for VAT to be charged in addition, a taxable person cannot claim to deduct an amount of VAT for which it has not been charged and which it has therefore not passed on to the final consumer. Read more

In Embiricos v HMRC the Court of Appeal has provided clear guidance on the circumstances in which a partial closure notice can be issued by HMRC to bring finality to a discrete aspect of an enquiry.  Although the decision was concerned with a dispute regarding domicile status, it has broad application and is therefore essential reading for those tasked with handling an HMRC enquiry. Read more