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Tax Administration and Key Principles

  • Veltema v Langham, CA 2004, 76 TC 259; [2004] STC 544; [2004] EWCA Civ 193
  • Discovery assessment; whether HMRC permitted to issue one; tax return submitted with valuation subsequently found to be incorrect
  • Scorer v Olin Energy Systems Ltd
  • Whether the previous agreement computations by the Inland Revenue precludes them from raising a subsequent discovery assessment.
  • R (oao Prudential plc) v Special Commissioner (and related applications)
  • Tax investigations, whether legal and professional privilege could be claimed in respect of certain documentation requested by HMRC during the course of an inquiry
  • Cenlon Finance Company Ltd v Ellwood
  • Whether the previous agreement of an appeal by the Inland Revenue precludes them from raising a subsequent discovery assessment.
  • Walton v R & C Commrs; [2009] TC 00273
  • Amendments to Self Assessment return by HMRC; whether taxpayer had discharged burden of proving incorrect assessments.
  • HMRC v Khawaja
  • Level and quality of proof required by HMRC when levying penalties
  • W.T. Ramsay v CIR
  • Artificial series of steps inserted purely for the avoidance of tax. This is a key case and, together with the case of Furniss v Dawson is a mainstay of HMRC in tackling artificial tax avoidance schemes on the basis of substance over form.
  • Furniss v Dawson
  • Artificial series of steps inserted purely for the avoidance of tax; consolidated the Ramsay principle established in the case of W.T. Ramsay v CIR
  • British Transport Commission v Gourley
  • The Gourley Principle - Whether an award for loss of earnings should be paid to the recipient before or after taking into account tax.

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