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CASES
Each week we report the tax cases that matter. Tax Journal subscribers have unrestricted access to the full archive, covering hundreds of cases.
Other cases that caught our eye: 11 October 2024
RD tax credits denied: In Strictly Money Ltd v HMRC [2024] UKFTT 866 (TC) (20 September), the judge dismissed the entire RD claim on the basis that no meaningful work was done in respect of the 1.4m expenditure on which...
D Hill and another v HMRC
Reliance on advisers held not to be reasonable excuse.
C Brzezicki v HMRC
Mixed-use rates of SDLT applied.
Andrew Quay Hull LLP v HMRC
ADR exit agreement was binding and enforceable.
Other cases that caught our eye: 4 October 2024
VAT on legal services: In Visual Investments International Ltd v HMRC [2024] UKFTT 843(TC) (19September), the FTT dismissed an appeal against assessments disallowing VAT on legal services the appellant had claimed as input tax. In particular,...
Brindleyplace Holdings S.à r.l (BP Holdings) v HMRC
No SDLT due on distributions of partnership and its properties following purchase of JPUT holding structure.
UK v Commission
ECJ annuls EC’s ruling on UK CFC group financing exemption.
Aramark Ltd v HMRC
FTT upholds HMRC’s application of NIC host employer provisions.
Other cases that caught our eye: 27 September 2024
Tax liability declaration rejected: The question of the correct procedure for dealing with loss claims where relief is claimed for a year which is not the same as the year in which the loss occurred has been a source of considerable litigation. The...
European Commission v Ireland and others
ECJ sets aside General Court’s State Aid judgment.
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384
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: The loans to participators regime no more (re)paying your way
FA 2025 review: VAT on private school fees: a lack of clarity