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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.
Lloyds Asset Leasing Ltd v HMRC
FTT denies cross-border group relief claim on main purpose grounds.
S Fitzgerald and another v HMRC
SDLT MDR denied where planning restriction existed.
Sarabande v HMRC
Input VAT recovery on supply of land.
Another case that caught our eye: 14 February 2025
Reasonable excuse and reliance on third party: In Xcel Consult Ltd v HMRC [2025] UKFTT 96 (TC) (30 January), the taxpayer was arguing that she had a reasonable excuse defence in her appeal against a VAT surcharge because she had relied on her...
M Ashley v HMRC
High Court considers subject access rights under UK GDPR in context of tax enquiry.
AAA Oriental Ltd v HMRC
Sch 36 information notice upheld.
Other cases that caught our eye: 7 February 2025
Employee loan arrangements: FS Capital Ltd and others v A Adams and others [2025] EWCA Civ 53 (28 January) is yet another twist in the long saga of employee loan arrangements and their resolution. It is not a tax case as such but will be of interest...
Bryan Robson Ltd v HMRC
IR35 and image rights.
Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC
Arrangements relating to animation
project were disqualifying for EIS.
Other cases that caught our eye: 31 January 2025
FTT decision on SDLT upheld: C Halstead v HMRC [2025] UKUT 22 (TCC) (15 January) is a decision of the UT refusing an application by the taxpayer to appeal against a decision of the FTT. We are now starting to see publication of the decisions in...
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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: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way