In A Outram and another v HMRC [2021] UKFTT 126 (TC) (27 April 2021) the taxpayers who knowingly entering into an avoidance scheme were found to have acted deliberately with a view to claiming non-existent losses with the intention to mislead HMRC and claim repayments of tax based on an avoidance scheme that they did not understand (the Pendulum scheme).
In Dodika Ltd and others v United Luck Group Holdings Ltd [2021] EWCA Civ 638 (7 May 2021) overturning the High Court's decision the Court of Appeal held that the Buyer had provided the Seller with the necessary 'reasonable detail' of a matter giving rise to a claim under the Tax Covenant.
J Tenconi v HMRC [2021] UKFTT 107 (TC) (3 April 2021) concerns the definition...