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CASES

Each week we report the tax cases that matter. Tax Journal subscribers have unrestricted access to the full archive, covering hundreds of cases.

Supreme Court finds advisers’ fees were capital in nature.

CA holds that stapled entity not entitled to double tax relief.

UT overturns FTT finding of deliberate behaviour as error of law.
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...
CJEU confirms that supplies between VAT groups are outside the scope of VAT.
HICBC assessment was ‘protected’.
FTT dismisses taxpayer’s public law arguments against CIS determinations.
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...
Paddock did not form part of grounds of dwelling for SDLT purposes.  
Taxpayer’s attempt to avoid full IR35 hearing on previously untested procedural grounds is rejected.
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