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Each week we report the tax cases that matter. Tax Journal subscribers have unrestricted access to the full archive, covering hundreds of cases.
Centrica Overseas Holdings Ltd v HMRC
Supreme Court finds advisers’ fees were capital in nature.
HMRC v GE Financial Investments
CA holds that stapled entity not entitled to double tax relief.
A Outram and another v HMRC
UT overturns FTT finding of deliberate behaviour as error of law.
Other cases that caught our eye: 26 July 2024
Carried interest base cost shift: In NMillican v HMRC [2024] UKFTT 618 (TC) (5 July), the FTT upheld the taxpayers appeal that his disposal of an interest in a company did not fall within the special regime in the TCGA 1992 which applies...
Finanzamt T II v S
CJEU confirms that supplies between VAT groups are outside the scope of VAT.
J Woods v HMRC
HICBC assessment was ‘protected’.
The Oaks (Gatley) Ltd v HMRC
FTT dismisses taxpayer’s public law arguments against CIS determinations.
Other cases that caught our eye: 19 July 2024
Collagen drink not food for VAT purposes: There have seen many cases over the years about the boundaries between cakes and biscuits for VAT purposes but the dispute in Bottled Science Ltd v HMRC [2024] UKFTT 592 (TC) (4 July) was over a more...
HMRC v T Suterwalla and another
Paddock did not form part of grounds of dwelling for SDLT purposes.
Jelly Vine Productions Ltd v HMRC
Taxpayer’s attempt to avoid full IR35 hearing on previously untested procedural grounds is rejected.
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371
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Burlington in the UT: a clearer approach
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Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
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Centrica Overseas Holdings Ltd v HMRC
HMRC v GE Financial Investments
A Outram and another v HMRC
Other cases that caught our eye: 26 July 2024
Finanzamt T II v S
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