In HMRC v Hyrax Resourcing Ltd [2021] UKFTT 212 (TC) (8 June 2021) the FTT dismissed HMRC's application for specific disclosure. In the context of whether it was reasonable for the taxpayer to have relied on the advice of a third party which was supported by the advice of leading tax counsel to the effect that the arrangements were not notifiable under the disclosure of tax avoidance scheme (DOTAS) rules the disclosure requested by HMRC was not required for a fair determination of the issues and in some cases it would have little probative value.
In E Balnakeil v HMRC [2021] UKFTT 193 (TC) (5 May 2021) expenditure on restoring listed building found to have been capital in nature because it was work on the replacement of substantially the whole of the building. Categorisation as repairs for VAT purposes...
