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APPEALS
Contentious tax quarterly: Spring 2025
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) review lessons from several important procedural decisions and a successful challenge to HMRC’s approach to subject access requests.
Advanced Hair Technology Ltd v HMRC
Hair transplant services did not qualify for VAT exemption
HMRC v Asset House Piccadilly Ltd
FTT considers meaning of ‘promoter’ in DOTAS regime.
Other cases that caught our eye: 28 February 2025
Adequacy of reasons given by FTT: In H Rafferty v HMRC [2025] UKUT 63 (TCC) (19 February), the taxpayer was given limited permission to appeal to the UT against closure notices, assessments and penalties. The decision of the UT in rejecting the...
Chemidex Generics Ltd v HMRC
Appeal allowed on IP valuation and amortisation period.
HMRC v The Taxpayer and others
Taxpayer loses right to confidentiality.
The last word on tax appeals
Malcolm Gammie CBE KC
The Supreme Court stands at the head of the UK’s judicial appeals system.
Malcolm Gammie CBE KC (One Essex Court) examines when permission
to appeal to the Supreme Court is likely to be granted, and considers how
taxpayers and HMRC are faring in securing permission.
HMRC v S&L Barnes Ltd
Upper Tribunal allows HMRC’s IR35 appeal.
HMRC v Labeikis and others
High Court strikes out Part 8 loan charge claims.
Case management before the tribunal
Dan Williams
Adam Craggs
Adam Craggs and Dan Williams (RPC) consider the various stages
involved in an appeal to the First-tier Tribunal and focus on the FTT’s case
management powers throughout the process.
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5
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
Urgent action could be required on non-dom ‘double remittances’
HMRC set out Pillar Two territories
Additional information requirements for creative industry claims updated
Private schools VAT challenge
HMRC increase late-payment interest rates
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
HMRC v Bolt Services UK Ltd
Other cases that caught our eye: 4 April 2025
HMRC v Innovative Bites Ltd and another
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
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
Concerns remain over Making Tax Digital
HMRC closing in on tax avoidance (again)
V Louwman v HMRC
B Lynch v HMRC