ANTI-AVOIDANCE

Carried forward losses: In Blackfriars Hotel (UK) Holdings Ltd v HMRC [2024] UKFTT 1095 (TC) (6 December 2024), the FTT considered an appeal by the taxpayer against a decision of HMRC to deny the use of carried-forward non-trading loan relationship...

Sale of LLP capital accounts not subject to income tax.

Sale of occupation income tax charge upheld.

Gideon Sanitt

Victoria Braid

The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).

Dominic Stuttaford

Aiden Hepworth

Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright) assess the practical impact of the Upper Tribunal’s decision in Gould.

Etienne Wong

Etienne Wong (Old Square Tax Chambers) provides a guide to the key points from the Labour government’s introduction of VAT on private school fees.

Thomas Chacko

The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).

Ross Birkbeck

With an estimated tax gap of some £36bn, Labour does seem to be taking enforcement seriously, writes Ross Birkbeck (Old Square Tax Chambers).

Oliver Marre

Just as we contemplate the demise of the remittance basis, Oliver Marre (5 Stone Buildings) examines the first Upper Tribunal decision on a key provision on those rules.

Zoe Andrews

Mike Lane

Recent decisions on intra-group VAT services, loan relationship debits and distributions from non-UK resident company are examined by Mike Lane and Zoe Andrews (Slaughter and May).

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