Author Archives: taxatlincolnox

About taxatlincolnox

Tax PhD candidate, College Lecturer and Tutor at Oxford University; Researcher at King's College London and Social Sciences Tutor with the Brilliant Club. With this blog, I seek merely to contribute to the debate. All thoughts are mine, of course.

The Margin of Appreciation in Tax Law

In a recent article for the British Tax Review (see here for Peacock, ‘The “Margin of Appreciation” Afforded in the Tax Tribunals: is there any Limit to Judicial Deference?’ (2017) BTR 404), Jonathan Peacock QC explores recent caselaw where taxpayers … Continue reading

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The latest twist in the Mansworth v Jelley tale

Late on Wednesday afternoon, the Court of Appeal handed down judgment in the case of R (Hely-Hutchinson) v HMRC [2017] EWCA Civ 1075. It is the latest twist in the long running saga concerning what has come to be known … Continue reading

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The language of tax avoidance cases

The opening line of single Supreme Court judgment in UBS v HMRC [2016] UKSC 13 from Lord Reed reads as follows: “In our society, a great deal of intellectual effort is devoted to tax avoidance. The most sophisticated attempts of … Continue reading

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Yet another case concerning APNs

Accelerated Payment Notices (‘APNs‘) have been frequently visited as a topic on this blog (see here, here, here, and here). To recap, APNs require taxpayers to pay disputed tax upfront before proceeding with an appeal (provided that certain conditions are … Continue reading

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Legal philosophy and a “voluntary” obligation to pay taxes

Legal philosophers (and philosophers more generally) have a beautiful way of cutting through the noise and expressing in the simplest language that which takes us mere mortals thousands of words to explain. This clarity presents itself of course whenever these … Continue reading

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Tax Exceptionalism – A UK perspective

In July 2016, I was tasked with responding to a presentation on “Trends in Tax Exceptionalism and Tax Litigation” by Professor Kristin Hickman of the University of Minnesota and Donald Korb of Sullivan and Cromwell. The event was organised jointly … Continue reading

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Studies in the History of Tax Law

The Centre for Tax Law at the University of Cambridge hosts a biannual Tax History conference. Papers selected for the conference are reviewed, edited and later published in the collection “Studies in the History of Tax Law” (published by Bloomsbury) … Continue reading

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Publication in the Bulletin for International Taxation

I have recently published a short article in the Bulletin for International Taxation entitled “The Relationship between Tax Authorities, Large Multinationals and the Public”, the abstract for which reads as follows: In this article, the author explores accusations levelled at the … Continue reading

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Remember that Swiss/UK Tax Cooperation Agreement? Vrang v HMRC [2017] EWHC 1055

I have written previously about the 2011 Swiss/UK Tax Cooperation Agreement (‘the Agreement’), which provided for UK resident taxpayers with bank accounts in Switzerland: to be subject to a one-off payment on 31 May 2013 to clear past unpaid tax … Continue reading

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Reflections on the Mansworth v Jelley hearing in the Court of Appeal

The author of this blog has written previously about the fabled ‘Mansworth v Jelley’ losses. It has been the feature of an extended published case note and two blogposts (here and here). The Court of Appeal heard the appeal in … Continue reading

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