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First tier Tribunal
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First tier Tribunal
FIRST-TIER-TRIBUNAL
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Tanja Velling (Slaughter and May) reviews a significant FTT decision in
which the taxpayers were denied interest deductions on a loan created in an
intra-group reorganisation under the unallowable purpose rule.
Generator Power Ltd v HMRC
Costs refused because HMRC’s behaviour was not unreasonable.
Alternative dispute resolution and mediation
Adam Craggs
Liam McKay
We are likely to see a consistent increase in the use of mediation in tax
disputes. Adam Craggs and Liam McKay (RPC) explain when and how it is
in the taxpayer’s interests.
Collins Construction Ltd v HMRC
FTT rejects HMRC’s interpretation of contracted out expenditure in R&D rules.
M Murphy and another v HMRC
FTT finds that sub-sale avoidance scheme failed.
Capital allowances: a question of design?
Paul Farey
Paul Farey (AECOM) considers the impact of the Upper Tribunal’s ruling in
the
Gunfleet Sands
case.
G Ives v HMRC
Property transactions not taxable and
PPR available.
Carelessness and the requirement of causation
Ben Blades
Recent cases have diverged on the question of whether HMRC must establish that carelessness caused a loss of tax, writes Ben Blades (Gray’s Inn Tax Chambers).
Lead cases in the tax tribunal: the rule 18 procedure
Anastasia Nourescu
Matthew Greene
Matthew Greene and Anastasia Nourescu (Stewarts) explain what the rule 18 lead case procedure is, review recent case law clarifying its scope and set out a few practical tips for advisers.
Private client review for March 2023
Hriday Munim
Edward Reed
Two victories for HMRC over claims for SDLT relief and another couple of wins in relation to discovery assessments, are among the developments reviewed by Edward Reed and Hriday Munim (Macfarlanes).
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
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
Read all
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
Read all
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
Read all
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
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
Autumn Budget 2024: IHT winners and losers
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Apprenticeship Levy and Employment Allowance: new employer guidelines