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    Crucial Issues in Tax Disputes: Event Agenda

    The Barrister Group
    Post by The Barrister Group
    July 19, 2024
    Crucial Issues in Tax Disputes: Event Agenda

    On September 5th, Exchequer Chambers, part of The Barrister Group, will host its first tax law seminar in the Inner Temple.

    The event will feature talks by a number of leading tax practitioners, and tickets can be purchased here.

    Event Agenda

    9.00am -
     

    9.30am -

    • Panellists discuss each of the 5 key lessons learned in their respective practices
    • Insight from highly experienced practitioners
    9.50am - (Andrew Thornhill KC - Barrister, Exchequer Chambers)
     
    • Key issues
    • Key pitfalls
    10.10am - (David Francis - Partner, Grant Thornton)
     
    • Types of ‘enquiries’
    • Strategy for resolution
    • The importance of Disclosure
    • Managing the information flow
    10.25am - (David Francis - Partner, Grant Thornton)
     
    • Upstream compliance
    • Topical trends
    • Disclosure facilities
    10.40am - (Annis Lampard - Tax Director, Deloitte & Karmjit Mader - Director, Deloitte)
     
    • What is Deliberate behaviour?  
    • HMRC’s Fraud Investigation Service  
    • Contractual Disclosure Facility - Code of Practice 9 
    • Consequences deliberate behaviour – assessments, penalties and other implications.
    • How is HMRC asserting deliberate behaviour outside of Code of Practice 9
    11.05am -
     
    11.15am - (Hugh Gunson - Partner, Charles Russell Speechlys)
     
    • Time limits
    • Carelessness vs deliberate behaviour / causation
    • “Acting on behalf of”
    • The officer condition
    • Practical points
    11.30am - (Julian Hickey - Barrister, Exchequer Chambers & Judge Nigel Popplewell - Judge, First Tier Tax Tribunal)
     
    • Strategic review – key issues
    • Key points on preparing and completing grounds of appeal (and making amendments)
    • HMRC’s Statement of Case – key issues and particularisation
    • Skeleton arguments / Purpose and preparation
    • Key aspects of preparation: evidence / witness recollection / burden of proof / standard of proof – what the tribunal is looking for on the issues
    • Case management issues through to the hearing
    • Appeals – navigating permission to appeal in FTT and UT – what to look for and why
    • Costs regime
    12.45pm -
     
    1.00pm -
     
    1.45pm - (Harry Smith - Senior Associate, RPC)
     
    • Evidence / Relevance / Admissibility / Disclosure of documents: scope of legal professional privilege
    • Undertaking a review of documents
    • Inspection of documents: practical issues
    • Witness statements
    • Specific Disclosure Applications: purpose and limitations
    2.10pm - (Jesminara Rahman - Director, Tax Resolute)
     
    • Outline of ADR process
    • Changes in ADR
    • Key Issues
    • Key Pitfalls
    2.35pm - (Peter Mason - Barrister, Exchequer Chambers)
     
    • Key issues
    • Key pitfalls
    3.00pm -
     
    3.15pm - (Judge Nigel Popplewell - Judge, First Tier Tax Tribunal)
     
    • What characteristics you are likely to find in an FTT Judge before whom you appear
    3.40pm - (Richard Clayton - Barrister, Exchequer Chambers)

    • Key issues
    • When available / Jurisdiction
    • Grounds for Judicial Review
    • Illegality
    • Irrationality
    • Legitimate Expectation
    • Fairness
    • Practice and procedure: High Court and Upper Tribunal
    • Importance of pre-action protocol letter
    • JR and Tax – key cases
    • Key pitfalls and how to avoid them
    4.15pm - (Hugh Gunson - Partner, Charles Russell Speechlys & Julian Hickey - Barrister, Exchequer)
     
    • Mistake and rectification – winding back the clock:
    • Conditions
    • “Artificial tax avoidance”
    • FTT vs High Court – who has jurisdiction?
    • UK vs offshore courts – differences in approach?
    • Procedure
    • Professional Negligence
    5.00pm -
     
    5.15pm -
     
    6.30pm -

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