CASES

Individual match contracts were not contracts of employment

Statutory residence: transit exemption and exceptional circumstances

HMRC’s unreasonable conduct not sufficiently unreasonable for indemnity costs

Discovery, debt assignment, distribution and penalties: In S Thomas v HMRC [2026] UKFTT 627 (TC) (24 April), the FTT decided that when the company assigned to its controlling shareholder a debt of £2.1m owed to the company by a third party, the...

DTT anti-abuse provision did not deny UK withholding exemption  

EBT was not remuneration

Invalid discovery assessment concerning failed SDLT scheme.

Dwelling for SDLT purposes: In Shinebrook Ltd v HMRC [2026] UKFTT 602 (TC) (16 April), the FTT ruled that Multiple Dwellings Relief (MDR) from SDLT was not available in relation to the purchase of a former commercial property, on which planning...

Capital allowances not available for environmental studies expenditure

Profits arose from oil extraction activities