Monthly Archives: January 2015

What the DPT tells us about politics…

Yesterday at the OUCBT conference on Diverted Profits tax (‘DPT’), the ‘respondents’ on behalf of the government (Philip Baker QC and Mike Williams of the Treasury) were quick to point out that the DPT was aimed at contrived, artificial arrangements. … Continue reading

Posted in Tax Law | 2 Comments

Are Accelerated Payment Notices unconstitutional?

Some commentators have been apocalyptic about the introduction of Advanced Payment Notices (‘APNs’). The APN regime broadly requires that taxpayers pay disputed tax upfront, before being able to challenge HMRC’s assessment through the normal channels. It is certainly ‘game changing’ … Continue reading

Posted in Tax Law | 2 Comments