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Closure notice
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Closure notice
CLOSURE-NOTICE
Other cases that caught our eye: 24 January 2025
Host employer regulation and control test: Odfjell Technology (UK) Ltd v HMRC [2025] UKFTT 28 (TC) (9 January) is the third recent case on the operation of the host employer regulations. These apply (broadly) where somebody is employed by an offshore...
The sale of occupational income provisions following Grint
Oliver Marre
The
Grint
case illustrates that HMRC may use the sale of occupational income provisions in even vanilla cases of tax planning, writes Oliver Marre (5 Stone Buildings).
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...
Other cases that caught our eye: 5 July 2024
Amortisation of goodwill: Although Armour Veterinary Group Ltd v HMRC [2024] UKFTT 539 (TC) (13 June) is a case about corporation tax relief for the amortisation of goodwill it will be of more interest to partnership practitioners. This is...
Back to basics: Closure notices and the appeals process
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) provide a refresher guide.
Other cases that caught our eye: 17 May 2024
Post-cessation trade relief/notice of enquiry into return: There are two distinct aspects to A Dennison v HMRC [2024] UKFTT 364 (TC) (2 May 2024). The substantive issue is whether or not the taxpayer was entitled to claim relief under the...
J Harjono and another v HMRC
Mixed-use SDLT appeal failed
Acorn Venture Ltd v HMRC
Capital allowances on camping pods.
Civic Environmental Systems Ltd v HMRC
Disregarding carry-back loss claim in closure notice appeal.
Getting closure: the FTT’s approach in Hitchins
Sophie Rhind
Victoria Braid
Sophie Rhind and Victoria Braid (Macfarlanes) examine when the tribunal
will exercise its power to direct HMRC to issue a closure notice in light of the
recent case of
Hitchins.
Go to page
of
2
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
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Tax Journal authors for March
HMRC closing in on tax avoidance (again)
Finance Act 2025 enacted
MPs press ahead with NICs increases
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St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
HMRC v Bolt Services UK Ltd
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HMRC v Innovative Bites Ltd and another
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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?
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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
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