Abuse of process, misconduct by HMRC

Appeal in FTT against amendments made by closure notices

Application for permission to appeal FTT decision

Application to set aside approval

Claim for terminal loss relief

Contract settlement

Appellant seeking to challenge the contract

Application to strike out an appeal

Declaration as to construction of tax avoidance provisions, transfer pricing

Determination of domicile

England/Scotland, comity

First-tier Tribunal to consider legitimate expectation and other public law arguments

Foreign revenue matters

Information notice

Appeals should not be stayed pending a preliminary hearing

Continued failure despite imposition of daily penalties pursuant to FA 2008, Sch. 36, para. 39

Documentation and information requirement

Failure of respondents to comply with the requirements of notices

First-tier Tribunal (FTT), one appeal struck out and one partly struck out

Penalties imposed by Upper Tribunal

Under Finance Act 2008 ('FA 2008'), Sch. 36

No jurisdiction to consider fixed penalties to be proportionate, First-tier Tribunal

No jurisdiction to hear appeal on decision on error or mistake relief, First-tier Tribunal (FTT)

Preliminary point: appeals against terminating rulings

Procedural guidance on management of legal issues in complex cases

Right to appeal abolished by secondary legislation

Right to notify appeal to tribunal