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Assessments
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ASSESSMENTS
Other cases that caught our eye: 15 November 2024
SDLT assessment and closure notice: The Wool House Ltd v HMRC [2024] UKFTT 997 (TC) (30 October) is quite an administrative tangle. The taxpayer paid SDLT on the normal single-property basis but then put in an overpayment relief claim, on the basis...
Rebel without a causal link: HMRC’s position on proving carelessness
Sophie Rhind
Victoria Braid
Mainpay
should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
Other cases that caught our eye: 11 October 2024
R&D tax credits denied: In Strictly Money Ltd v HMRC [2024] UKFTT 866 (TC) (20 September), the judge dismissed the entire R&D claim on the basis that ‘no meaningful work’ was done in respect of the £1.4m expenditure on which...
Andrew Quay Hull LLP v HMRC
ADR exit agreement was binding and enforceable.
Go City Ltd v HMRC
Attraction pass was outside the scope of VAT when sold.
P Marano v HMRC
Court of Appeal considers validity of automated notices and assessments.
Other cases that caught our eye: 1 March 2024
No hardship with VAT assessment: A taxpayer wishing to appeal to a tribunal against a VAT assessment must either pay the disputed tax up front or apply to HMRC or the tribunal for permission not to pay the assessment on grounds of hardship. SC...
HMRC’s assessment powers: key considerations
Matthew Greene
Guy Bud
HMRC’s assessment powers vary depending on the tax at issue but there are common themes, write Matthew Greene and Guy Bud (Stewarts).
P Hunt and others v HMRC
Application for a stay.
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Nuel Oji
Stuart Walsh
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
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Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
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3 /7
Freebies
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4 /7
Time is tight: CGT and the Autumn Budget
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5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
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Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
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HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
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R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
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Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
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Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
Apprenticeship Levy and Employment Allowance: new employer guidelines
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC