CASES

Privilege preserved despite sharing between firms

Quay wall capital allowances ruling set aside 

When is a liquid supplement a drink?  

Victory for taxpayers relying on extra-statutory concessions  

Nudge letter did not open an enquiry: In K Shariff v HMRC [2026] UKFTT 1498 (TC) (28 October), the FTT rejected the taxpayer’s preliminary argument that HMRC had invalidly opened two enquiries into the same return. The earlier nudge letter amounted...

Director’s loan novation constituted a taxable release

Electrical substation established mixed-use treatment for SDLT

Who is supplying what to whom?

Loan settlement did not discharge income tax liability: In S Fullerton v HMRC [2026] UKFTT 1479 (TC) (26 October), the FTT dismissed the taxpayer’s appeal against a discovery assessment and carelessness penalty arising from the release of her...

Legitimate expectation and the builders’ block